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2 March 2011 External T.I. 2010-0377321E5 F- Jeux de hasard sur Internet-- summary under Exempt Receipts/Business Summary Under Tax Topics- Income Tax Act- Section 9- Exempt Receipts/Business on-line internet gambling winnings non-taxable if no business Respecting winnings of an individual from daily gambling at an internet casino, CRA stated, after discussion inter alia Leblanc: [W]here a given activity does not constitute a source of income, neither the amounts received nor the expenses incurred in connection with that activity should be included in computing the taxpayer's income and any excess of expenses over revenues is personal expenses or living expenses that are not deductible under paragraph 18(1)(h). ...

6 April 2006 External T.I. 2005-0157461E5 F- Frais de déplacement- actionnaire-- summary under Paragraph 18(1)(h) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(h) expenses of corporate investor to attend shareholders’ meeting were non-deductible In finding that airfare and hotel expenses incurred by an investment company to attend a general meeting of shareholders in connection with one of its share investments were non-deductible, CRA stated: [T]he travel and living expenses incurred are not deductible to the corporation on the basis that, in our view, the expenses incurred by a shareholder of a corporation in attending the annual meeting constitute personal and living expenses within the meaning of paragraph 18(1)(h). ...

A "lodge" for this purpose means an inn or resort hotel, particularly one that is a centre for recreational activities, as well as a dwelling occupied on a seasonal basis in connection with particular activities, such as hunting or fishing. ...

2 October 2001 External T.I. 2001-0102655 F- T5008- AGENT DE L'ACHETEUR-- summary under Subsection 230(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 230- Subsection 230(2) trader or dealer is not required to file a T5008 re purchases made for clients In connection with finding that a trust company acting as agent for a purchaser of stock-exchange shares pursuant to a public offering need not file a T5008 slip pursuant to Reg. 230(2) or (6), CCRA stated: [A] purchase as principal is a purchase made for the purchaser's own account. ...

2 October 2001 External T.I. 2001-0102655 F- T5008- AGENT DE L'ACHETEUR-- summary under Subsection 230(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 230- Subsection 230(6) purchase made as agent does require filing a T5008 In connection with finding that a trust company acting as agent for a purchaser of stock-exchange shares pursuant to a public offering need not file a T5008 slip pursuant to Reg. 230(2) or (6), CCRA stated: [Reg.] 230(6) … would not apply to a person who acts as an agent or nominee to effect a purchase for a person who is not a trader or dealer in securities as defined in [Reg.] 230(1) …. ...

4 April 2002 External T.I. 2001-0104065 F- PROVISION D'ENTREPRISE DANS UNE PROVINCE-- summary under Subsection 2601(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 2601- Subsection 2601(1) Quebec partner who retired and became an Ontario employee allocated the reserve inclusion under s. 34.2(5) wholly to Ontario An individual left a Quebec partnership in 1998 to take up employment in Ontario and ceased to have any connection to it or any other source of business income in Quebec in 1999. ...

11 June 2002 External T.I. 2001-0104075 F- DEDOMMAGEMENT-- summary under Paragraph 18(1)(e) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) damages award not recognized until appeal thereof heard Regarding whether an award of damages against the taxpayer in connection with its construction of a manufacturing plans was contingent and, thus, not to be added to the plant’s cost in light of such judgment being under appeal, CCRA indicated that an amount should not be recognized if its payment was subject to awaiting the decision of a higher court. ...

29 June 2020 External T.I. 2018-0782541E5- Employee Life and Health Trusts-- summary under Subsection 144.1(4) Summary Under Tax Topics- Income Tax Act- Section 144.1- Subsection 144.1(4) contributions not deductible under s. 144.1(2) may be deductible under s. 9 CRA noted that if a trust did not qualify as an employee life and health trust (ELHT) under s. 144.1(2) or if payments in connection therewith did not constitute employer contributions to an ELHT: the premiums paid and contributions made would not generally be deductible by participating employers pursuant to subsection 144.1(4) of the Act but could be deductible as an expense incurred for the purpose of gaining or producing income from a business. ...

16 November 2000 External T.I. 2000-0035815 F- OPTION D'ACHAT D'ACTION-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date CCRA could not accommodate re-doing the exercise of stock options Regarding whether the taxpayer could modify the transactions carried out in connection with the exercise of a portion of the taxpayer’s stock options followed by the sale of those shares, CCRA stated that “the tax treatment applicable to a taxpayer always depends on the transactions actually carried out” and that it was not possible “to apply the Income Tax Act to allow a taxpayer to obtain the tax treatment that the taxpayer would have wished to obtain if the taxpayer had had all the necessary information before carrying out his transactions.” ...

A will hold 20%, their son will hold 25% and unrelated third parties will hold the remaining 30%, the family ties would reasonably indicate common connections, or acting in concert, with the result that there will be an acquisition of control by a new group comprising Mr. and Mrs. ...