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Regarding a luncheon registration fee paid by a lawyer for a conference on recent case law, CRA stated (before going on to refer to the s. 67.1 limitations): Generally, the registration fees incurred by an individual in connection with a luncheon seminar are deductible in computing income from a profession under subsection 9(1) provided that they are incurred to maintain, update or upgrade a skill for the purposes of that profession and are reasonable in the circumstances. ...

(a) of “advantage,” and also could give rise to an “RCA strip,” as the payment for life insurance coverage reduces the FMV of the subject property of the RCA trust each year as the amount paid for this protection is not invested in property held in connection with the RCA trust,” CRA then stated: In a situation where it is reasonable to attribute a portion of a decline in the FMV of the specified property of the RCA to an advantage relating to it, the custodian of the RCA trust would be unable to make an election under subsection 207.5(2) unless the Minister is satisfied that it is just and equitable in the circumstances to permit that election to be made. ...

In connection with his return to Canada as a resident, he is contemplating transferring assets to a non-resident trust. ...

As such, in the hypothetical scenario described, given that US Parent, which is the sole trustee of the Trust, wholly owns US Opco, being the beneficiary of the Trust, and thus controls US Opco, in our view, US Opco may be considered a “person related thereto” in respect of the Trust for the purposes of paragraph 3 of Article XXIX-A in connection with Canadian taxes to which the Treaty applies. ...

Art. 12 of the Canada-U.K Treaty exempted copyright royalties, but there was an exclusion from this exemption for payments in respect of motion pictures or of works on film, videotape or other means of reproduction for use in connection with television broadcasting. ...

X was not usually engaged in activities that could earn him a profit in connection with those items. ...

. … [S]upplies [under s. 8(1)(i)](iii)] would not include the cost of tools or equipment or amounts paid for a cell phone connection or communication licence fee. ...

In connection with Mr. X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...

In connection with Mr. X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...

In connection with Mr. X selling Aco and Bco to two unrelated purchasers (HoldcoA and HoldcoB), who each wanted 50 of the units: Aco transferred 30 units to Bco on an s. 85(1) rollover basis in consideration for Bco preferred shares (the “Subject Shares”) with an FMV of $30,000. ...