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(at para 42)) rather than their cost – although, here, the denied operating expenses and CCA of the corporate owner "can be used to establish the value of the benefit conferred on Mr. ...

A's father, CRA indicated that there would be no taxable benefit respecting such use by the father for the years under review before the effective date of s. 15(1.4)(c) – but thereafter, the value of the benefit enjoyed by the father was taxable to the son (Mr. ...

Canco paid Japanese income tax on the capital gain reported on such disposition and also reported a capital gain for Canadian tax purposes – but later determined (with CRA's concurrence) that the fair market value of the shares had been nil. ...

. …. If, in the case described, there in fact is an allocation of capital gains of the SEC to its partners, we believe it would be difficult to maintain that they do not retain their character in the hands of the latter, including the Limited Partner. ...

. … Canco was deemed to realize a gain in Year 3… equal [to] the total of amounts deducted by Canco under paragraph 113(1)(d) in respect of Forco dividends received through LP that were paid out of Forco's pre-acquisition surplus, less any foreign tax paid in respect of Canco's share of those dividends. ...

. … [I]n 2009-033576, there was no withdrawal from the RRSP. ...

And finally: … only the part of the property taxes attributable to the renovation period that are related to the ownership of the land subjacent to the building, as well as any land meeting the requirements of subparagraph 18(3.1)(a)(ii), should be added to the cost of the building. ...

. … Consequently, a testamentary trust cannot designate a benefit in its income tax return without ensuring that it constitutes an amount that would have otherwise been eligible under paragraph 60(j) for a beneficiary if the beneficiary had received it. ...

. … Usually…installation is seen as being performed in relation to a tangible property, such as a machine or equipment, and…installation should be the main activity of the project to qualify as an "installation project". ...

. … [T]he GAAR should not apply to the situation in this case because subsections 103(1) and (1.1) are of sufficient breadth to adjust the income-sharing terms agreed between the partners of the partnership. ...