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The Directorate further observed: [S]ubparagraph 6801(a)(vi) … does not allow the inclusion of deferred amounts to be extended where the leave has not commenced within the maximum period allowed pursuant to subparagraph 6801(a)(i) …. ...

The EPSP trust would use an interest-bearing loan from Employerco to fund its purchase of the matching number of Employerco shares and fund the loan interest with dividends on the shares and annual contributions from Employerco – both of which were taxable income to it but with an offsetting interest deduction, so that there would be no annual income inclusion to the participant under s. 144(3). ... Here, there is no profit-sharing in purpose or effect. … Furthermore, we note that the favourable tax results under the Proposed Transactions are similar, in large part, to those available under the employee stock option rules in subsections 7(1) and (1.1) and paragraphs 110(1)(d) and (d.1) of the Act, even though the Plan is not an employee stock option agreement, Employerco is not a Canadian-controlled private corporation, the Participant might not necessarily be dealing at arm’s length with Employerco, and the requirements of paragraph 110(d) or (d.1) are not satisfied. ...

[S]ubsections 118.1(16) and 110.1(6) … apply to reduce the fair market value of a gift by a donor to a private foundation, by the unpaid balance at the time of the gift, of any loan advanced by the foundation to the donor (or to persons or partnerships who do not deal at arm's length with the donor) prior to the time of the gift pursuant to an agreement entered into in the 60 months prior to the time of the gift. Subsections 118.1(16) and 110.1(6) of the Act also apply to any new loan provided by the foundation to the donor (or to persons or partnerships who do not deal at arm's length with the donor) within 60 months after the time of the gift. … [T]he Act does not provide for the reinstatement of a gift for purposes of subsections 110.1(6) and 118.1(16) of the Act in the event the property used by the donor or person not dealing at arm's length with the donor is returned (or repaid) to the donee. ...

Is it required to amend that return to include the claim amounts in its June 30, 2020 taxation year – or would CRA permit those amounts to instead be included in the subsequent year? a) CRA indicated that, under Candarel, “in ascertaining profit, the taxpayer is free to adopt any method which is not inconsistent with the provisions of the ITA, established case law principles or ‘rules of law’ and well-accepted business principles,” and then stated that inclusion of those amounts under s. 9 “would be … a method which would yield an accurate picture of the taxpayer’s profit for the taxation year ending on May 31, 2020.” ...

., to expose steeply-dipping mineralization) and digging test pits (for shallow mineralization) Definition or infill drilling, Resource estimation and deposit delineation, deposit modelling and updating resource estimates Testing of rock stability, of mineral resource dilution (re waste rock) and of metallurgy (re difficulty of separating pay material) including grinding tests Metallurgical separation testing on core or bulk samples (to determine recoverable percentage of minerals) – but not if for determining an optimal method of separation Bulk sampling (in reasonable sizes) for determining the effective grade (after dilution), performing grinding tests and whether any separation process (e.g. flotation or solvent extraction) allows minimum quality specifications- provided it is not for determining the optimal processing method Note: various of the above items do not qualify as CEE if they are performed for camp, infrastructure or mine design purposes. ... The following are deductible under s. 9 if incurred before making a decision to bring the mine into production (otherwise generally Class 41 or 41.2 assets or other depreciable property, or Class 14.1 if the property is not acquired – or CDE under para. ...

In our view, this condition is satisfied since [B[received income from his rental properties and the reimbursement received … related to those rental properties. ... [A] paid the amount … in the course of earning income from a business or property or with a view to obtaining a benefit for himself. ...

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We have rendered a similar decision in … 2008-0289751E5. ...

6 November 2007 Internal T.I. 2005-0152091I7 F- Frais de déplacement- activité de divertissement-- summary under Subsection 67.1(1) Summary Under Tax Topics- Income Tax Act- Section 67.1- Subsection 67.1(1) cost of transporting independent sales reps from an event was “in respect of … entertainment” The taxpayer provided periodic events for its top representatives, who were independent contractors. ...

., by virtue of subsection 6(1)(a)) in computing the taxpayer's income under Part I …. ...