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The Directorate responded: [Y]ou had already established in December 2005 that Mr. X had not declared an amount in his 2004 return (the "first criterion at issue "). ... X would be subject to a penalty pursuant to subsection 163(1) for his 2004 taxation year …. ...

During each of 2001 to 2005, ABCco had full rate taxable income ("FRTI") of $160,000. ... (a) and (b) of A in the GTIP addition formula for 2001 to 2005 for ABCco was $504,000. ... The result is the same whether the circular calculations begins with the $800,000 dividend paid by one of the corporations, or the other …. 4 th Situation This is identical to the 3 rd, except that, in 2004, ABCco paid a taxable dividend of $100,000 to its parent. ...

4 June 2014 External T.I. 2013-0513761E5- Meaning of "cost" in determining "equity amount"-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(5)- Equity Amount- Paragraph (c) "cost" not reduced by amortization Generally, … the "cost" of property …include[s] the amount laid down to acquire such property. … The Queen v. Canada Trustco Mortgage Company (2005 DTC 5523),…stated…that ‘[t]extually, the CCA provisions use ‘cost' in the well-established sense of the amount paid to acquire the assets….'…[T]he term "cost" for the purposes of the definition of "equity amount" in subsection 18(5)… means the original acquisition cost of a property. ...

11 October 2017 External T.I. 2016-0673171E5- Foreign tax credit- former resident-- summary under Subsection 126(2.21) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(2.21) emigration-year return generally cannot be opened up more than 6 years later to allow a FTC for foreign tax imposed on a subsequent sale A Korean individual became a resident of Canada in 2005 while owning Korean real property that had previously been purchased $600,000 and that had a fair market value of $1,000,000. ... …The Minister is not obligated to reassess a return simply because a waiver is filed by a taxpayer for a particular taxation year …. [A] blanket waiver request without sufficient details of a transaction would likely not be considered valid. … … 2016-066042 … opined that if any of the circumstances to support the deduction under subsection 126(2.21) of the Act (e.g., disposition of the property and/or foreign taxes paid) are present within the statutory assessment period referred to in paragraph 152(4)(b) of the Act, it may be appropriate for the Minister to consider a taxpayer’s waiver request for the emigration year to allow the Minister sufficient time to review and process any potential reassessment for this deduction beyond the aforementioned reassessment period. ...

CRA stated: [A]ssuming that after the acquisition of the shares, Subco would be merged with OPCO by way of an amalgamation or winding-up, we note that the Given Situation would be similar to the example given in paragraph 4 of Supplement 1 … IC 88-2. The CRA's position is generally not to apply subsection 245(2) in situations similar or identical to [such] example …. However, if Subco were not merged with OPCO following the acquisition of the shares, other elements may have to be considered …. ...

16 November 2006 External T.I. 2006-0203131E5 F- Régime à traitement différé-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) advances received were salary rather than loans and, when repaid, reduced employment income An employee signed a deferred salary leave contract for the period from June 29, 2002, to December 29, 2006, with his leave being taken from May 14 to November 11, 2005. ... Such prepaid salary (i.e., the amounts received while on leave) were required to be included in the employee's income for the year in which it was paid, i.e., the 2005 taxation year. However, in the year of resignation, i.e. 2006, since the salary for the last two pay periods was withheld to recover part of the prepaid salary, the amount of salary received by the employee- net of the deductions made by the employer – was to be included in the employee's income for 2006 In addition, any cheques written by the employee in 2006 for prepaid salary reimbursements would reduce his employment income for 2006 and, if repaid in 2007, would reduce the employee's 2006 employment income, so that the employer would be required to file an amended T4 slip for that taxation year. ...

The correspondent stated that “no amount could be determined for Target in respect of element I in the formula provided for in element H of subsection 89(8) since the definition of general rate income pool ("GRIP") is not applicable for the 2005 taxation year” suggested that there appeared to be an overstatement (from a policy perspective) of Target's LRIP “resulting from its inability to benefit from the GRIP balance that it would have otherwise enjoyed had its change in status occurred after January 1, 2006.” CRA responded: [S]ubsection 89(8) is technically applicable …. [R]esponsibility for tax policy … rests with the Department of Finance ….” ...

Canada (2005 FCA 334, para. 5) that the addition of section 8.1 of the Interpretation Act occurred for clarification purposes, and that this legislative amendment was not intended to change the state of applicable law. … [I]f it were determined that such a comparative analysis supported the conclusion that a US LLC must be considered as a partnership for the purpose of application of the Act, we suggest that it would not be appropriate to adopt a classification approach to entities and foreign arrangements which could result in a different classification according to the province or territory of the residence (or permanent establishment) of the taxpayer holding an interest in the entity or the arrangement. … [I]t appears to us, based in particular on the conflict of law rules, that the provincial and territorial laws of property and civil rights in Canada provide for mutual recognition of different types of entities or arrangements established under the respective jurisdictions of the various provinces and territories, thus providing an expanded base for analysis that is uniform across Canada for the purposes of applying the two-step approach. ...

In December 2005, the RRSP sold the shares for $1, and the corporation was insolvent. ... Given … Byram, we do not believe that Mr. A's loss should be deemed to be nil solely because the Corporation's shares were acquired by the RRSP and not personally by Mr. ...

. … We consider the 1994 judgment to be the only valid judgment up to the date of the letter …. That has the effect of allowing a deduction for the support payments actually paid for one of the children, pursuant to paragraph 60(b), for the 2001 to 2005 taxation years. ...