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CRA found that: [T]he Taxpayer’s right to reduce the Interest Debt … falls within the definition of a “right to reduce” in subsection 143.4(1) because it is reasonable to conclude, having regard to all the circumstances, that the right will become exercisable [i.e., that the conditions precedent would be thereafter satisfied]. ...

., the determination of whether the hypothetical particular person controls a corporation) for the purposes of paragraph (b) …. ...

26 January 2009 Internal T.I. 2008-0303901I7 F- Allocation raisonnable et coûts d'opération-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) Quebec government-mandated travel allowances are reasonable including re depreciation – if too low, can make s. 8(1)(h.1) claim A Quebec government employee, who in the course of her employment must travel to visit patients, receives an allowance of $0.43 per kilometre in accordance with the Government of Québec's Treasury Board Directive for travel allowances. ...

The Directorate stated: Prior to the issuance of the Exercise Notices, it is our view that Opco had no obligation to issue shares of its capital stock …. ...

Therefore … CanCo’s LRIP/GRIP balances (as applicable) would not be affected [and] subsection 214(16) would not alter the character of the income received by ForCo for FAPI purposes. ...

Consequently … a non-resident may offset a taxable capital gain on the disposition of TCP (other than treaty-protected property) with a net capital loss on the deemed disposition of property that was not TCP that arose when the taxpayer was a resident of Canada. ...

. … We are of the view that the amount of the class action provision relates to policies in the context of claims since it is by virtue of the rights arising from the XXXXXXXXXX insurance policies that the insureds who suffered a loss were able to bring the class action. ...

In the second case, there would be no benefit under s. 15(1), and also no benefit under s. 105(1) given that the shareholder was related to a beneficiary – whereas, in the first case, there could be a s. 15(1) benefit conferred by the corporation. ...

21 March 2005 Internal T.I. 2005-0119961I7 F- CCPC STATUS-- summary under Paragraph 251.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 251.2- Subsection 251.2(2)- Paragraph 251.2(2)(a) moving from one shareholder to 2 equal shareholders generally entails an acquisition of control unless there is deadlock USco disposed of 50% of the shares of Canco to another corporation ("Holdco" – that was a Canadian-owned Canadian corporation), "retroactive" to a particular date. ...

There is no provision in … the Regulations requiring an employer to make deductions in respect of the lump sum payment of a retiring allowance to a non-resident person. ...