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CRA indicated that the company providing the trips should issue T4A slips to the individual proprietor, or to the individual receiving the trip as a benefit qua employee of the individual’s personal corporation – whereas no T4A slip is required if the trip was received as a benefit qua shareholder of the personal corporation (a distinction which in practice would be difficult or impossible for the trip provider to apply). ...

In this regard, the T2 Corporation Income Tax Guide … states that the Part I tax payable for the year is the basic Part I tax plus the amount of surtax, the amount of recapture of the investment tax credit, and the refundable tax on the Canadian-controlled private corporation’s investment income, minus any allowable deductions and credits, including the federal tax credit for forestry operations. ...

The TSO proposed to designate pursuant to s. 80(16) the maximum amounts permitted under ss. 80(7) and (11), so that the forgiven amount would be applied first against the balance of the non-capital loss, second as to reduce ¾ of the cumulative eligible capital and third, to reduce the adjusted cost base of the related corporation shares under s. 80(11), resulting in an amount being deemed to be a capital gain from the disposition of capital property under s. 80(12). ...

The Directorate first stated: Although the T5003 "Tax Shelter Information Return" and the T5003 "Statement of Tax Shelter Information" slips are considered interdependent … each summary and slip is a separate information return. ...

. … [W]ith respect to meal allowances paid to employees who work outside their regular place of employment, it is necessary to determine whether the allowance is reasonable and whether it is paid while the employee is travelling in the course of performing the duties of the employee’s employment outside the municipality or metropolitan area where the employer's establishment in which the employee ordinarily works is located. ...

In 1998, the Canada Revenue Agency amended its policy …. Consequently, a facility does not include a golf club's dining room, reception rooms, conference rooms, lounges or bar so that the deduction of expenses incurred for the purchase of food and beverages at a golf club is no longer prohibited by subparagraph 18(1)(l)(i). ...

After noting that the s. 67.1(2)(f) exception applied only for purposes of s. 67.1(1), and did not override the prohibition in s. 18(1)(l), CRA went on to state: In 1998, the Canada Revenue Agency amended its policy …. ...

. … [T]he benefit determined under subsection 7(1) will be required to be added to the non-resident's employment income earned in Canada in the taxation year of the disposition of the Corporation C shares by virtue of subsections 7(1) and (1.1) and subparagraph 115(1)(a)(i). ...

. … [T]he Consent Fees are not management or administrative fees or charges…[and] are simply paid to retain the outstanding Credit Agreements. ...

Although the Taxpayer mostly had not deducted the amounts of the Interest Debt, in its return (apparently for Year X), the Taxpayer added such amounts to its non-capital losses at the beginning of the year – then in Year X+1, it deducted the forgiven amount, equalling the difference between the Interest Debt and the fair market value of its assets, from the balance of its non-capital losses. ...