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Thus, where an organization issues a reimbursement for an eligible expense that was incurred in the previous taxation year … that reimbursement reduces the amount of the eligible expense and that a receipt must be issued accordingly for the year in which the expense was incurred. ...

. … In addition, where a worker uses an automobile owned by the organization, not only for volunteer activities, but also for commuting to and from work, we are also of the view that this benefit does not give rise to tax consequences, provided that the cost of the automobile is reasonable and that it is the only personal use made of it. ...

CRA responded: if, in the year of death, a taxpayer has a net capital loss or any unused net capital losses carried forward from prior years, the special rules in subsection 111(2) concerning the application of paragraphs 111(1)(b) and 111(1.1)(b), as they are to be read under these circumstances, allow the deduction of such losses (less the amount of any capital gains exemption claimed by the taxpayer …) up to the amount of the taxpayer’s available income from all sources for the year of death and the immediately preceding year. ...

. … [W]hether the provision of a meal or the reimbursement of meal expenses is primarily for the benefit of the employer is a question of fact that can only be resolved after an examination of all the facts of each particular situation. ...

Subco will purchase for cancellation its 12 common shares held by Independentco, for cash – or, alternatively, Subco will pay a cash dividend out of its safe income on hand, and Independentco will dispose of its commons shares of Subco to Sisterco for cash. ...

Furthermore, our Directorate's position is to decide on the potential application of section 84(2), section 84.1 or section 245(2) on a case-by-case basis …. ...

11 August 2006 External T.I. 2006-0195781E5 F- Bourses de perfectionnement-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) changed tests for distinguishing employment following Sagaz and Wolf Before going on to indicate that Natural Sciences and Engineering Research Council of Canada fellowships paid to host organizations to cover $30,000 of the minimum $40,000 cost of engaging graduates to engage in authorized research projects likely were employment income “because of the relationship of subordination that appears to exist between the … recipient and the host organization,” and after referring to the Sagaz and Wolf decisions, CRA stated: As a result of these judgments, the CRA has developed an approach to assess the overall relationship between the parties to determine the nature of the working relationship. ...

. … Generally, a corporation is resident at the place where it is actually managed and controlled. ...

Whether there is a gift is a question … of civil law. 3. Where, in the context of a transfer of property, the general rules of contract and obligation and all the specific conditions of a gift in civil law are satisfied, we are of the view that the gift will generally be considered a gift for the purposes of the Act. ...

. … Given that the purpose of paragraph 67.1(2)(c) is to exempt the taxpayer only where the payer is subject to subsection 67.1(1), we are of the view that the words "specifically notified in writing" used in the wording of paragraph 67. 1(2)(c) assume that there is no ambiguity as to the amount subject to subsection 67.1(1) in the hands of the payer, in order for the taxpayer to be able to rely on the exemption in paragraph 67.1(2)(c). ...