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The Directorate, in noting that “[i]t is possible that the person paying salary or wages is not the employer,” repeated the statement in Mollenhauer “that subsection 153(1) … does not speak of whether persons doing the paying are employers or not,” and went on to find that the individuals likely were employees of Cco, so that the charges from Bco for their salaries likely could be included in the “cost of labour” of Cco under Reg. 5202. ...

Consequently, the functions or services performed by the subcontractors do not fall within the definition of "cost of labour" …. ...

15 April 2004 Internal T.I. 2004-0062451I7 F- Résidence principale-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (c) no need to file form for principal residence portion of disposed-of property if it was fully exempted A taxpayer disposed of land in excess of ½ a hectare, did not file a Form 2091, did not report any capital gain, and on audit was unable to demonstrate that the excess land was necessary for the use and enjoyment of the residence, so that there was a capital gain on the disposition of such excess land. ...

Paragraph 23 of Interpretation Bulletin IT-337R4 explains the limit …. ...

Before finding that it qualified under Class 6(e) as a storage tank, the Directorate indicated that the storage tank did not fall within Class 8(c) as the Directorate did “not believe that the settling tank is a building and that it was acquired for the purpose of "manufacturing or processing" as … decantation is not a physical or chemical change produced by a technique of preparation or handling but rather a change resulting from a natural process.” ...

The CRA's position in this regard is that the condition set out in subparagraph 108(2)(a)(i) is not satisfied where the suspension of redemption rights exceeds one year (see, among others, documents # E 2000-0007513, E 941673, E 933222 and E 913030). ...

Before finding that such incentive payments were includable in the income of such clients under s. 12(1)(x) (absent any election made under s, 12(2.2) respecting the premiums paid) given inter alia that they were received by such clients “in the course of earning income from … property,” namely, acquiring and holding the policies, CRA cited La Capitale (98 DTC 6215) (also regarding an insurance policy) for the proposition that "’property’ in the Act includes practically any type of economic interest” and indicated that “the Policyholder holds property for the purposes of the Act.” ...

Before going on to indicate that such fees were not deductible under s. 60(o) by the shareholder, the Directorate noted that they would have been deductible by the corporation if incurred by the corporation – but were not deductible under s. 9 by the individual since he was not carrying on a business. ...

. … [T]he 2004-2005 T4130 no longer states that reasonable living expenses are limited to a maximum of 15 days. ...

In finding that the grant amounts should be included in capital under s. 181.2(3)(a), the Directorate stated: [T]he net amount of … government grants, which is not a loan or advance, constitutes funds that the government has injected into the taxpayer. ...