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The Directorate stated: Given that the remuneration of the Employees and the portion of the EI employer's contribution paid by the taxpayer are personal expenses for the taxpayer, we are of the view that a SBJC amount would not be an amount included in computing the taxpayer’s income …. ...

. … After the end of the limitation period, the CRA may not take collection actions; however, the debt remains payable by the taxpayer and the CRA will accept payments on account of the debt. ...

. … Accordingly, the de-registration of an individual’s TFSA would cause a permanent loss of TFSA savings room for the individual. ...

. … Furthermore, nothing in the wording of section 85 allows the CRA to require a taxpayer and a taxable Canadian corporation to file an election or an amended election. ...

15 December 2011 Internal T.I. 2011-0413891I7 F- Récupération d'amortissement-Recapture CCA-- summary under Subsection 13(1) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(1) successive business and property income use of rental property reflected in apportionment of source of ensuing recapture A holding corporation earned deemed active business income under s. 129(6) from renting a building to an associated corporation for two years, and thereafter earned property income from renting the property to a non-associated corporation – and then disposed of the property, thereby realizing recapture of depreciation. ...

CRA confirmed that the capital cost of the depreciable property to the corporation would exceed the property’s FMV at the time of the transfer – so that if the property were sold immediately thereafter for its FMV, the corporation could incur a terminal loss, and if it were sold a few years later for an amount exceeding that determined under s. 13(7)(e)(i), there would be a capital gain and no recapture. ...

That prohibition on use should generally be evidenced in writing …. In such a case, the benefit for reasonable standby charges should be calculated on the basis that the Automobiles are made available to the executive employees for a period of 7 months per year. ...

28 October 2010 Internal T.I. 2010-0376041I7 F- Contrat d'acquisition ou de location-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A lease where lessee got benefits of ownership even if it didn’t acquire title not necessarily a lease Motor vehicle lease agreements provide that the lessee will automatically acquire ownership after making specified rent payment, and with the payment of an often nominal residual value – and if the lessee decides not to acquire, any excess of the sales proceeds are credited to it by the lessor After indicating that generally “re-characterization of legal relationships is only possible where a taxpayer's designation of the transaction does not adequately reflect its true legal effects,” CRA stated: [W]hether a contract is a purchase contract or a lease contract should be resolved primarily on the basis of the legal relationships created by the terms of the agreement. ...

21 September 2010 Internal T.I. 2010-0377011I7 F- Dépenses de vêtements- travailleur indépendant-- summary under Paragraph 18(1)(h) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(h) no deduction to self-employed welder for work boots and fire-resistant clothing In finding that the cost to a self-employed welder of purchasing steel-toed work boots and fire-resistant clothing could not be deducted in computing his business income, CRA stated: [W]here a taxpayer acquires clothing that can be used in both the taxpayer's business and personal activities … the expense is a personal or living expense that is not deductible by reason of paragraph 18(1)(h). ...

. … Our position might be different if these boots and clothing were used by the self-employed worker only in the course of performing the worker’s welding activities. ...