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" 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. ...

Before describing the application of the s. 248(21) or (20) rules to a partition and consolidation of the shares if the co-ownership interests therein had first been transferred to the spousal trust, CRA indicated that s. 70(6) could not apply if the partition of the shares was effected between X and the estate before the transfer of divided shares to the spousal trust, stating: [T]he property held by Y prior to his death, i.e. the undivided interest in shares, would not be the same property as the property received by the spousal trust in connection with the partition effected by the Estate, i.e. shares. ...

.- PART PRIVILÉGIÉE-- summary under Subparagraph 53(1)(e)(i) Summary Under Tax Topics- Income Tax Act- Section 53- Subsection 53(1)- Paragraph 53(1)(e)- Subparagraph 53(1)(e)(i) division of partnership interest into preferred and common units does not affect determination of partnership interest’s ACB In connection with a query on the implications of holding a preferred unit in a partnership, i.e., a unit that confers on its holder a preferred share of the partnership's profits or losses, CRA stated: The total of the units held by a partner in a partnership constitutes a single property which is the partner's interest in the partnership. ...

Repairs or Running Expense Belgega-finding that inducement paid to prospective emphyteuta (tenant) was capital expenditure- noted Regarding a payment made by a landowner to a related corporation as an inducement to enter into a contract granting a right of emphyteusis, CRA noted that Befega, 72 DTC 6170 found that expenses incurred in connection with an emphyteusis were capital expenditures, that were not deductible in computing income because they were made not only once and for all but also to provide an enduring benefit to the business, and then reiterated its position that it must be determined whether a tenant inducement payment was incurred for the specific purpose of producing an identifiable item of income so as to engage the matching principle or whether it gave rise to sufficient current benefits to be treated as currently deductible. ...