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14 July 2014 Internal T.I. 2014-0537701I7 F- Voluntary disclosure- T1134 and FAPI-- summary under Subparagraph 152(4)(b)(iii) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(b)- Subparagraph 152(4)(b)(iii) Ho acknowledged In connection with a failure of a taxpayer to report foreign accrual property income, CRA noted that the application of s. 152(4)(a)(i) is a question of fact, and then stated: The same applies to the application of subparagraph 152(4)(b)(iii), which involves a transaction entered into between the taxpayer and a non-resident person with whom the taxpayer was not dealing at arm's length. ...

28 April 2004 Internal T.I. 2004-0067561I7 F- Impôt de la partie I.3-- summary under Paragraph 87(2)(a) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(a) no IT-474, para. 10 relief for acceleration of Part I.3 tax In connection with the taxpayer’s reference to the statement in IT-474, para. 10 that “[w]here the provisions of paragraph 87(2)(a) produce unintended consequences which are unfavourable to the taxpayer, the Corporate Rulings Directorate … is prepared on a case by case basis to consider whether relief is appropriate,” the Directorate indicated that no such relief was available respecting an acceleration of Part I.3 tax resulting from an amalgamation. ...

15 March 2005 Internal T.I. 2004-0108721I7 F- Don d'une licence-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property excepting WIP, definition of property is no broader than term’s ordinary meaning In connection with finding that a gift of a non-exclusive software licence was a gift of property, CRA stated: In Manrell, the Court went on to determine that, with the exception of paragraph (d) (which is not relevant to this case), the definition in subsection 248(1) does not have the effect of giving the word "property" a meaning that differs from its ordinary meaning. ...

19 October 2005 Internal T.I. 2005-0151211I7- Financing expenses-- summary under Paragraph 20(1)(e) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e) reimbursement by sub Can a subsidiary corporation, D Co, deduct, under s. 20(1)(e), reimbursement payments paid to its indirect parent corporation, A Co, respecting expenses incurred by A Co in connection with the issuance of debentures of A Co? ...

20 June 2007 Internal T.I. 2007-0233551I7- Deductibility of Transaction Costs-- 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 Professional fees (including fees for audit services) incurred by a Canadian-controlled private corporation in connection with a proposal to convert to an income trust that did not proceed, were found to be eligible capital expenditures. ...

18 February 2013 Internal T.I. 2013-0477821I7 F- Montants forfaitaires- XXXXXXXXXX-- summary under Section 3 Summary Under Tax Topics- Income Tax Act- Section 3 damages received in wage discrimination suit for pain and suffering were non-taxable In discussing the treatment of lump sums paid to federal employees following a finding by the Human Rights Tribunal that a discriminatory practice had been committed at their workplace and pursuant to a settlement agreement concluded with the Treasury Board, CRA first stated that if the amounts “represent compensation for loss of salary, they constitute income from an office or employment,” and then stated: [W]ith respect to the amount … for pain and suffering under paragraph 53(2)(e) of the Canadian Human Rights Act … this amount qualifies as general damages received in connection with a human rights violation and may therefore be considered to be unrelated to the employment of the Workers. ...

13 May 2014 Internal T.I. 2013-0499041I7- Subparagraph 149(5)(e)(ii)-- summary under Subsection 149(5) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(5) sale of largely vacant land A private member golf club disposed of the land located across the street from the main entrance which was vacant except for a pump house which formerly had been used in connection with irrigating the golf course but now was purportedly held as a backup s]water source (to pump water from the adjacent river) if the primary water source failed. ...

On the other hand, the cost of a property may include legal fees, commissions, brokerage fees, and any other expenses that were incurred directly in connection with the acquisition of the property or that were incurred for the purpose of disposing of the property. ...

Repairs or Running Expense Costs incurred, apparently by a purchaser,in connection with the clean-up of environmentally contaminated land (apparently, vacant land) was considered to be on capital account on the basis that they related to the preservation or improvement of a capital asset. ...

Unlike paragraphs (a) and (b) of that definition, there is no requirement that the SR&ED be performed in Canada in connection with manufacturing or processing in Canada of goods for sale or lease. ...