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For instance, in Year X4, the income of Investco was tainted because in its last taxation year (X3) it had received dividend income from Opco and, in any event, the taxable capital gain realized by it in that year was deemed by s. 120.4(1.1)(d)(i)(B) to be income derived from the Opco business. ­­­­­­­­­­­­­­­ ...

12 September 2019 External T.I. 2019-0802301E5- Annuity purchased from foreign pension-- summary under Subsection 147.4(1) Summary Under Tax Topics- Income Tax Act- Section 147.4- Subsection 147.4(1) s. 147.4(1) permits non-inclusion where annuity is purchased out of RPP Before noting that s. 147.4(1) does not apply to annuities purchased from foreign pension plans, so that a retiree- whose former non-resident employer determined to wind-up a foreign pension plan by using funds in the plan to purchase annuity contracts for each retired member – was required under s. 56(1)(a)(i) to include the full fair market value of the annuity in income in the wind-up year, CRA stated: Where the conditions in subsection 147.4(1) are met, the individual is deemed not to have received an amount from the RPP as a result of acquiring the annuity and any amounts received under the contract are deemed to be amounts received under the RPP. ...

CRA concluded: [I]t does not appear that these amounts would constitute income from a source, including social assistance under paragraph 56(1)(u) …. ...

. …. [P]ublic institutions would generally include municipalities and local governments, Crown corporations, wholly owned municipal corporations, public universities, public colleges, public schools, health authorities and hospitals. ...

7 April 2020 External T.I. 2019-0832241E5- Deferral of lump sum retiring allowance-- summary under Subparagraph 56(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(a)- Subparagraph 56(1)(a)(ii) retiring allowance can be elected, on or prior to termination, to be received and recognized in a subsequent year Respecting a query as to the tax implications of paying a retiring allowance to a terminated employee in the calendar year following the year of termination at the election of the employee, CRA referred to its position in Folio S2-F1-C2, para. 2.26 that an employee can choose, on or before termination of employment, to receive a lump sum in instalments – which are taxable in the years of receipt, and stated: This position applies equally where payment of the lump sum is deferred to a subsequent year, provided that the individual chooses the deferred option on or before termination of employment. ...

After noting that under a joint tenancy, “the joint tenants have concurrent ownership and possession of the same property,” CRA stated: [W]here two or more joint owners of a share of a corporation are considered one shareholder under relevant corporate law or are entitled to jointly receive any dividend paid on the share by the corporation, the joint owners of the share will generally be counted as one shareholder for purposes of paragraph 130.1(6)(d) …. ...

15 September 2020 External T.I. 2020-0854471E5- Pension Corporation- Renting Furnished Apartment-- summary under Paragraph 132(6)(b) Summary Under Tax Topics- Income Tax Act- Section 132- Subsection 132(6)- Paragraph 132(6)(b) renting furnished apartments was an exclusively real-estate leasing activity S. 149(1)(o.2)(ii)(A)(II) permits a s. 149(1)(o.2) (pension-group) corporation to invest its funds in “a partnership that limits its activities to acquiring, holding, maintaining, improving, leasing or managing capital property that is real property or an interest in real property … owned by the partnership”. ...

Amounts paid to the employee for such travel must therefore be included in computing the employee's income … [and] the employee cannot deduct personal travel expenses in computing income from an office or employment. ...

., a desk or chair) – but that the $500 limitation applies to all such equipment on a per employee basis so that, for example, where the employer reimburses the $400 and $250 cost of a desk and computer monitor, respectively, CRA will consider the $150 excess over $500 to be a taxable benefit. ...

Therefore, as the amount is calculated for an eligible employee in respect of a week in the qualifying period, it is our view that the qualifying entity has discretion to claim a lesser amount in its application by excluding any employees from the wage subsidy calculation under subsection 125.7(2) …. ...