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The Directorate found that this note disclosure was sufficient to amount to the grants being reflected in the taxpayer’ balance sheet, stating that the “net amount of grants … is therefore identifiable on the balance sheet and, consequently, paragraph 181(3)(b) requires that that amount be used to determine the taxpayer's capital in subsection 181.2(3).” ...

Consequently, the individual would be deemed to have received a dividend pursuant to subsection 84(1) equal to the amount by which the increase in the PUC … of the preferred shares exceeds the amount by which the PUC of the common shares is reduced. ...

On the other hand, if he acquired the mortgage in the course of a business of purchasing debt obligations, the amount of the discount was only to be included in his income after he had fully recovered his purchase price – although it was acceptable to compute a gain as being realized on the receipt of each blended payment. ...

However, paragraph 6(1)(l) … allows a benefit relating to the operation of an automobile to be included in the income of an employee of a member of a partnership since the employee enjoys the benefit because of the employee’s employment. ...

Consequently, we are of the view that paragraph 67.1(2)(c) would apply in those cases …. ...

In rejecting the retroactive application of this provision, the Directorate stated: Although an order dated after April 1997 may deem or stipulate that child support amounts payable or receivable after that date will be subject to the pre-May 1997 support rules … we are of the view that such tax consequences do not arise because an order has so stipulated. ...

16 August 2001 Internal T.I. 2001-0079317 F- RESIDENCE PRINCIPALE DEMI-HECTARE-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (e) exemption could be claimed only for one lot/ CCRA does not normally challenge contribution to enjoyment of residence of under ½ hectare if no commercial use The taxpayer acquired a lot on which he constructed a residence and also used in part for business purposes and also acquired an adjoining lot on which he erected buildings used for business purposes. ...

Furthermore … the damages do not represent employment income. The amounts received for material and moral damages would therefore not be taxable. ...

Furthermore, “suretyship is generally distinguished from insurance on the basis that the latter compensates for a loss that may arise from a future and uncertain event, whereas suretyship generally covers an existing obligation to a creditor” – so that the partnership was not providing insurance. ...

This has the effect of applying the old rules on support, which means that Monsieur could deduct the amounts paid and Madame would be taxed on the amounts received under that judgment …. ...