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CRA provides a general discussion of the application of the Act to the deemed contribution of property to a trust of which the bare owner and usufructuary are the beneficiaries, and of the application of s. 107(2.1) to the winding up of the trust in connection with the termination of the usufruct. ...

CRA provides a general discussion of the application of the Act to the deemed contribution of property to a trust of which the bare owner and usufructuary are the beneficiaries, and of the application of s. 107(2.1) to the winding up of the trust in connection with the termination of the usufruct. ...

3 April 2014 External T.I. 2013-0512371E5 F- Qualification des montants gagnés au jeu de poker-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit on-line poker winnings were from more than a pastime In connection with concluding that a taxpayer, who began to devote a substantial portion of his time to online poker gambling, earned income from a business, and after quoting from IT-334R2, paras. 10 and 11, CRA stated (TaxInterpretations translation): [W]here the principal source of income of a taxpayer is on-line poker games (as compared to other taxpayers who are employed full time and indulge in poker in their free time), such taxpayer is considered to derive business income from such games. ...

" During a Municipality employee’s temporary assignment to a position of employment with Entity, Municipality agreed to continue making an automobile available to such employee (“Employee”) in connection with such temporary employment. ...

CRA responded: [W]e are generally of the view that there would be a benefit under paragraph 6(1)(a) if the amounts received by the employee have any connection with his or her employment. ...

CRA responded: [W]e are generally of the view that there would be a benefit under paragraph 6(1)(a) if the amounts received by the employee have any connection with his or her employment. ...

6 February 2012 External T.I. 2012-0434071E5 F- Honoraires professionnels- PDV-- summary under Paragraph 60(o) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(o) professional fees incurred under VDP are deductible under s. 60(o) once CRA commences its review Regarding the deductibility of professional fees incurred in connection with a voluntary disclosure of undisclosed foreign investments, CRA stated: [P]rofessional fees incurred to make an application under the VDP are not deductible under paragraph 60(o). ...

That would generally be the case where compensation is for loss of earnings, renunciation of the reinstatement of employment and other benefits including the costs of seeking new employment, where there is a connection between the loss of employment and such payments. ...

26 July 2010 External T.I. 2009-0349481E5 F- 212(1)d)(i)-Marque de commerce utilisée au Canada-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) royalty for use outside Canada of trademark is subject to withholding Canco, which sells consumer goods to retailers, acquires a licence to use a trademark in connection with the sale of goods in Canada or the U.S. from an arm’s length U.S. licensor (the "Licensor"), with the licence providing for the payment of royalties to the Licensor based on the number of production units sold. ...

. … A benefit received as a consequence of the death of a person qualifies as a death benefit if it can reasonably be regarded as being paid in recognition of services rendered by that person in connection with an office or employment. ...