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CCRA stated: Where paragraphs 1, 2 and 3 of Article XIII of the [Canada-US] Convention do not apply … paragraph 5 of Article XIII of the Convention may apply to a U.S. resident who disposes of property acquired on an amalgamation referred to in subsection 87(1) of the Act, even if that property replaces property that was the subject of a deemed disposition pursuant to paragraph 128.1(4)(b) of the Act when that taxpayer ceased to be resident in Canada. ...

24 May 2001 External T.I. 2001-0069045- SHORT SALE AND IDENTICAL PROPERTIES-- summary under Subsection 47(1) Summary Under Tax Topics- Income Tax Act- Section 47- Subsection 47(1) "... ...

Profit- Short Sales "... We would consider a short sale entered into in order to hedge a taxpayer's position with respect to identical shares held on capital account to be a short sale that is on capital account. ...

Regarding the resulting disposition of the spousal beneficiary’s income interest, it indicated that there would be no amount to include in the beneficiary’s income pursuant to s. 106(2) as s. 106(3) would apply – but s. 106(3) would have no adverse consequences assuming that the property distributed was cash. ...

In addition … an amount declared by a cooperative to be a patronage dividend to a member, computed on the basis of the volume of work performed directly or indirectly by that member for the cooperative, would be a deductible amount pursuant to subsection 135(1) since it would meet the definition of "allocation in proportion to patronage". ...

CCRA responded: [A] designation filed by a corporation pursuant to paragraph 88(1)(d) in its return of income under Part I of the Act for its taxation year in which its subsidiary was wound-up, in a situation similar to the one … described, could not be considered invalid solely because the amount designated by the parent corporation was overstated. ...

. … [I]f a trust governed by an RRSP or a RRIF continues to hold property after December 31, 2001 to which paragraph 4900(1)(s) of the Regulations applied, the tax that the trust will have to pay under Part XI.1 of the Act will be computed at 1% of the fair market value of the property at the time it acquired it. ...

CCRA indicated that the standby benefit would be computed based on the corporation’s cost of $22,500 and the number of 30-day periods during which the automobile is available to the employee – unless the kilometres driven personally was fewer than 1,000 kilometres per month and all or substantially all (i.e., 90%) of the distance travelled by the automobile during the total number of days in the year it was made available to the employee was in the performance of the duties of his employment. ...

(e) exclusion, stating that “the goods or equipment to be transported by the motor vehicle … must be distinct from the motor vehicle itself.” ...

In either case, the entire amount should be included in income on December 15, 1999, the date the advance was received … [per] paragraph 28(1)(a). ...