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The Directorate responded: [T]he CRA … allows a taxpayer who owns two or more rental properties that are located in two or more locations other than the taxpayer's principal residence to deduct reasonable travel expenses incurred in collecting rents, supervising repairs, and managing the property. Generally, we consider that a taxpayer who owns a single rental property is not carrying on a business and, as a result, the taxpayer’s travel expenses are considered personal and therefore not deductible. … Benjamin … 54 DTC 357 … determined that travel expenses incurred by a taxpayer to attend to rental properties are personal expenses of the taxpayer. The CRA does, however, provide relief for a taxpayer's reasonable motor vehicle expenses incurred by the taxpayer to transport tools and materials to a rental property to perform all or part of the repair or maintenance work on the taxpayer’s rental property, provided that the property is located in the taxpayer's home area. … It should be noted that this policy does not provide relief for travel expenses to collect rents if the taxpayer has only one rental property and is not carrying on a business. ...

James, 66 DTC 5241for the proposition that “a request for an adjustment to the computation of net income to create a non-capital loss or increase such loss by taking into account the business losses realized during the 1995, 1996 and 1997 taxation years would be acceptable even if a new notice of assessment cannot be issued for those years,” and then stated: Pursuant to subsection 122.5(3), the GSTC is an amount “deemed to have paid during the specified month on account of their tax payable under this Part for the taxation year …”. Under subsection 152(1), the Minister reviews the return of income, assesses the tax and determines “the amount of tax … deemed by subsection … 122.5(3) … to be paid on account of the taxpayer’s tax payable under this Part for the year.” ...

. … [W]here a trust files a T3 return and does not report having a permanent establishment or income in a particular Agreeing Province … the trust has reported nil income with respect to the particular province or territory. Furthermore, the resulting Notice of Assessment or notice of no tax payable is considered to include a notice of no tax payable in respect of the Agreeing Province. … Accordingly … the federal assessment constitutes a Notice of Assessment or notification of provincial or territorial tax for all Agreeing Provinces. ... This view is consistent with … Aubrey Dan Family Trust …. Words and Phrases agreeing province ...

18 May 2000 Internal T.I. 2000-0006037 F- FRAIS D'ACQUISITION-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing commissions directly related to the acquisition of a life insurance policy are generally deductible in the year incurred CCRA indicated that “the matching principle mentioned in … IT-417R2 as well as the Agency's comments on the Canderel and Toronto College decisions set out in Income Tax Technical News No. 16 [and] … F9913160 … do not apply to acquisition expenses incurred by an insurer” (i.e., life insurance policy acquisition expenses, including commissions directly related to the acquisition of the policy) but indicated that generally, those expenses are deductible in the year in which they are incurred. ...

9 July 2024 Internal T.I. 2023-0976691I7- Film Tax Credit and Alter Ego Trust-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership the property of an alter ego trust “belonged” to its sole trustee and life beneficiary rather than to the trust In order for a fee paid to a corporation for the executive producer servicers of an individual employed by the corporation to qualify for the B.C. production services tax credit, there was a requirement (essentially copied from ITA s. 125.4(1) – labour expenditure – (b)(iii) and s. 125.5(1) – Canadian labour expenditure- (b)(iii)) that the shares of the corporation “belong” to a BC-based individual – whereas, here, the shares were held by the individual in his capacity of trustee of an alter ego trust which had been settled by him (to avoid B.C. probate duties) and of which he was the life beneficiary. In finding that this shareholding satisfied the above “belong to” test, rather than the shares belonging to the trust, the Directorate stated: [T]he shares … belong to [the individual] and not the Trust for purposes of the tax credit. ... {Here] … [the individual] has legal ownership of the shares in [the individual’s] role as trustee, and beneficial ownership of the shares as the sole beneficiary who is entitled to the income on the shares while [the individual] is alive …. ...

X …. The Residence would therefore have been disposed of by [them to] Mrs. X …. Regarding the verbal agreement … it is up to the taxpayer to demonstrate the existence of such an agreement whose effect is to transfer the ownership of the Residence at a particular time other than on XXXXXXXXXX. If the taxpayers can provide evidence to you of that verbal agreement, you should consult … Legal Services …. ...

. … Example 2 … Mr. A is present in Canada for 212 days in 2015, and the income of the partnership derived from his services is more than 50% of the gross active business revenue of the partnership ($200,000 / $350,000 = 57.14%) during those 212 days. ...

After noting that this structure appeared to be intended to maximize the small business deductions by the five managementcos, CRA stated: According … Hughes Homes … 98 DTC 1082 … taxpayers have the burden of demonstrating that the fundamental reasons for the existence of the corporations are not tax-related. … [I]t seems unlikely that the corporate structure was put in place by the Individuals for reasons other than tax: … an operating corporation is created and used for each of the projects involving a real business risk; the payment of management fees to the management corporations instead of the payment of dividends (if the Operator had paid dividends, the management corporations would have been specified investment business corporations); … 4 out of 5 of the individuals are related by blood. ...

B cannot claim the children's amount in respect of any of her children since …she is not entitled to the wholly dependent person credit in respect of them and … none of the children ordinarily reside throughout the year with her and another parent. … [I]t is Mr. A who would be entitled to the child amount under paragraph 118(1)(b.1) for both children … since … he would be able to claim the wholly dependent person credit for his two children if paragraph 118(4)(a) did not apply to him for the year. … [U]nder paragraph 118(4)(a), Mr. A would not be able to claim the wholly dependent person credit in respect of more than one of his children …. ...

The Directorate responded: Since the lump sum in this case was not paid in lieu of amounts payable periodically as described in paragraph 22 of … IT-530R … that amount is not a support amount within the meaning of subsection 56.1(4). ...