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In indicating that the vehicles likely qualified as “automobiles,” CCRA stated that this determination turned on “the design of these motor vehicles and not … their use.” ...

5 February 2003 External T.I. 2003-0183055 F- PARTIE 1.3 ACTIF UTILISE-- summary under Paragraph 181.4(a) Summary Under Tax Topics- Income Tax Act- Section 181.4- Paragraph 181.4(a) future income tax asset is not an asset used or held by the corporation After paraphrasing s. 181.4(a), CCRA stated: [A] future income tax asset of a corporation is not an asset of the corporation "used … or held" by it and is not included in the taxable capital employed in Canada of a corporation for the purposes of section 181.4.... ...

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29 July 2019 External T.I. 2018-0784701E5- Rent from real/immovable properties- furnishings-- summary under Subparagraph 132(6)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 132- Subsection 132(6)- Paragraph 132(6)(b)- Subparagraph 132(6)(b)(ii) renting furnished apartments gave rise to rents All of the rent generated from a rental unit that was fully-furnished with “furnishings typically … found in a residence” would qualify as “rent from real or immovable properties.” ...

22 January 2020 External T.I. 2014-0559281E5 F- T5008-- summary under Computation of Profit Summary Under Tax Topics- Income Tax Act- Section 9- Computation of Profit cost of short sale is FMV of borrowed shares CRA indicated that in a short sale, the cost of the shares sold short is the fair market value of the shares at the time they are borrowed for the purpose of being sold short – so that the cost of the sales sold short is not the cost of the shares subsequently purchased to cover the short. ...

7 December 2022 External T.I. 2020-0846891E5 F- SSUC- Revenu admissible-- summary under Subsection 125.7(7) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(7) limited partner’s share of LP revenues cannot be qualifying revenue After quoting from the definition of “qualifying revenue,” CRA stated: [A] limited partner's share of the profits of a limited partnership, as allocated to the limited partner pursuant to subsection 96(1) and in accordance with the limited partnership agreement, is not "qualifying revenue" to the limited partner …. ...

. … Therefore, [under Reg. 2201(2)(b)] any payments of interest [as well as principal] made by the debtor after the Failure would be "on account of the obligation" and would so reduce it. ...

Respecting the deductibility of the “meal” portion of the charges to the trainees, CRA stated: [S]ince there is no exception that would allow participants to avoid the application of subsection 67.1(1) … the expenses they incurred for food and beverages paid during training, even if not identified separately, should be subject to the 50% limit in subsection 67.1(1). ...

20 March 2015 External T.I. 2014-0535971E5- Meaning of "paid-up capital" in subsection 90(3)-- summary under Paid-Up Capital Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Paid-Up Capital LLC with partner capital-account style LLC Agreement does not have PUC CRA stated that "to the extent [the applicable State corporate] laws and constating documents do not provide for stated capital akin to that which is provided for under Canadian domestic corporate law but, rather, provide for an attribute that is akin to a partner's capital account, [a] US LLC would not…have stated capital" – and therefore would have no paid-up capital for s. 90(3) purposes. ...

The corporation and partnership would not be affiliated under s. 252.1(1)(d), in light of the Southside principle that " Where one person controls the corporation, it is not possible to identify a group that controls the corporation. ...