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12 January 2011 Internal T.I. 2010-0375801I7 F- Bien agricole admissible détenu avant 1987-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property property status of Quebec lands divided into cadastral lots was analyzed on a lot-by-lot basis Before finding that Quebec lands that had been devised to a widow by her farmer husband, who used only part of the lands in his farming business, should be analyzed on a cadastral lot-by-lot basis, respecting meeting the tests in s. 110.6(1.3)(c)(ii), so that only those lots that had been used by deceased husband in farming so qualified, the Directorate stated: [C]adastral lots are considered, for the purposes of the Act, to be separate real property …. ...

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., Thomson Reuters Corporation and OANDA Corporation, whose rates are "generally acceptable"]; … used in accordance with well-accepted business principles; used for the preparation of the taxpayer’s financial statements; and used consistently from year to year by the taxpayer.... ...

In this case … this subsection can be applied to any taxation year that is not statute-barred subject to the application of subsection 152(4). ...

. … [T]he settlor, in this case the Employer, has not transferred any amount from its patrimony. ...

On the other hand, since Corporation A received advance payments in respect of goods processing services to be performed after the end of the taxation year, these amounts come within paragraph 12(1)(a) …. ...

The exception in s. 6(1)(b)(vii.1) was not available as the employees were not travelling in the performance of the duties of their employment, as to which the Directorate stated: In the absence of services rendered to the employer during the period of travel, the employee does not travel in the performance of the employee’s duties …. ...

Before finding that Non-Resident Corporation did not have a permanent establishment in any province for purposes of Part IV of the Regulations, the Directorate stated: Article XVI of the Convention … applies without regard to, inter alia, Article VII of the Convention, and... permits Canada to tax income derived by a non-resident company from performances in Canada without requiring that such income be earned through a permanent establishment in Canada under the Convention. ...

In the present case … [it] may be permitted in the context of a reassessment. ...

Given … Byram, we do not believe that Mr. A's loss should be deemed to be nil solely because the Corporation's shares were acquired by the RRSP and not personally by Mr. ...