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CCRA stated: [T]he Agency's position … is that a corporation that redeems shares held by one of its shareholders may pay its entire capital dividend account to that shareholder, provided that subsection 83(2.1) does not apply. ...

. … Provided that all the conditions of subsection 20.01(1) are satisfied and subsection 20.01(2) applies, an individual may deduct in computing income from a business an amount payable by the individual for the year as a premium to a private health services plan. ...

9 November 2000 External T.I. 2000-0038955 F- CLAUSE DE CAPACITE DE GAIN-- summary under Paragraph 12(1)(g) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) ascertaining 5-year earnout period / meaning of “calculated with certainty” Regarding the fourth earnout condition in IT-426, which stipulates that "the term of the contract must not exceed five years", CCRA indicated that this period commenced when the contract was formed in accordance with provincial law (which might be the date written on the contract), and that the period would generally not end at least until all payments to be made could be calculated accurately, and that the period could extend beyond this point, e.g., where there was a potential for subsequent adjustments. ...

When she stopped using one of the units as her personal residence and started renting it out, its cost for CCA purposes was stepped by ¾ under s. 13(7)(b)(ii)(B), and she would realize a capital gain pursuant to s. 45(1)(a). ...

28 April 2000 External T.I. 2000-0020695 F- CREDIT-BAIL-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A Construction Bérou not followed after 1990 – taxpayers generally should follow the legal form of the agreement The Agency referred to its position in Income Tax Technical News No. 5 of July 28, 1995: Generally, we will rely on the assumption that the form of an agreement reflects the true relationship between the parties. ...

. … [Here] a deduction of $100,000 should be made because of the capital loss realized by the corporation during the “relevant period.” ...

. … In the event that a corporation's business includes the making of loans but those loans cannot be viewed as having been made in the corporation's ordinary business of lending money, it is our view that those same loans cannot be considered as "debts that arose in the ordinary course of the creditor's business".... ...

. … It is the Department's long standing practice not to regard an offset of a shareholder's loan account debit balance against a dividend payable as part of a series of loans and repayments for purposes of paragraph 15(2)(b).... ...

1 December 2009 External T.I. 2009-0307821E5- TFSA Contributions- Options and Warrants-- summary under Paragraph 7(1)(c) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(c) contribution to TFSA – recognition deferred until exercise by TFSA What are the tax consequences of an employee stock option being contributed to a TFSA? ...

After noting that Cummings found “that the payment of fees to a real estate broker for finding tenants and entering into new leases is generally a current expense” and that Canderel found that “in order to obtain a better or a more accurate picture of the landlord's profit, the lease incentive payments were current expenses that were deductible in the year, and which were not subject to the matching principle because they brought significant and numerous benefits immediately in the year of payment,” CRA stated: [A]ssuming, of course, that this remuneration represents an expense of a current nature … the remuneration would be deductible in the years in which it is paid. ...