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It stated: The CRA's position is that expenses incurred in connection with the granting of an option may be deducted from the proceeds of disposition when calculating a taxpayer's gain. ...

26 May 2023 External T.I. 2023-0962521E5- Employment Expenses of a Pilot-- summary under Subsection 8(4) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(4) pilot potentially could deduct meal expenses pursuant to s. 8(1)(h) in connection with daily flying from and to the home city, provided that 12-hour requirement met A pilot incurred meal expenses while away from the municipality of the employer establishment where the pilot reported for work (the “home city”), and would fly back to the home city on the same day. ...

16 November 2000 External T.I. 1999-0009895 F- Revenu protégé- voiture de tourisme-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees reorganization expenses are eligible capital expenditures (now Class 14.1) Before confirming that no adjustment to safe income on hand was required in respect of eligible capital expenditures such as reorganization expenses, CCRA stated: Where reorganization expenses have been incurred in connection with a reorganization whose purpose is to preserve the entity, structure or commercial organization of the business, or whose purpose is to allow the continued existence, growth and development of the business, the Agency's position is that the expenses in question could be considered to be capital expenditures incurred for the purpose of earning income from the business and therefore eligible capital expenditures. ...

After discussing McGoldrick, CRA stated: [E]ven if the meals were provided free of charge to the Affected Employees in connection with the purposes of the business, their personal benefit in this respect cannot be incidental. ...

Additional relief in connection with reporting requirements may be available on a case-by-case basis under subsection 220(2.1). ...

Additional relief in connection with reporting requirements may be available on a case-by-case basis under subsection 220(2.1). ...

After noting that a "swap transaction" includes, in respect of a registered plan, any transfer of property between the plan and its controlling individual, subject to specified exceptions, and that the concept of "advantage" in s. 207.01(1) “specifically states that any benefit that is an increase in the total fair market value of the property held in connection with the registered plan is considered a benefit if it is reasonable to consider, having regard to all the circumstances, that the increase is attributable, directly or indirectly, to a ‘swap transaction’," CRA stated: Furthermore, the phrase directly or indirectly, used in the definition of advantage, includes (if that is the case) any immediate increase in the FMV of the registered plan resulting from the swap transaction, as well as any increase in the FMV of the registered plan that can be attributed to the initial swap transaction. ...

CRA stated: [T]here must be a connection between the actual travel expenses incurred by a taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs, in order for the amounts to be "...in respect of travel expenses incurred by the taxpayer... ...

25 September 2013 External T.I. 2013-0497011E5 F- OETC- Qualifying period-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) related preparatory and sick leave periods can be included in qualifying period computation An individual performed various preparatory work in Canada under a service contract for a qualifying activity for the purposes of the OETC, then worked abroad in connection with this contract for a little over five months, and then was granted sick leave and vacation on the return to Canada. ...

He does not come to Canada in connection with his work except on rare occasions such as an annual reunion. ...