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A in connection with her claim before the tribunal were non-deductible, the Directorate stated: [T]he legal fees were incurred to recover an amount belonging to Ms. ...

Examples include paragraph 20(1)(aa): amounts paid for landscaping of grounds, paragraph 20(1)(cc): amounts paid for expenses of representation, paragraph 20(1)(dd): amounts paid for site investigation, and paragraph 20(1)(ee): amounts paid for utility service connections. ...

5 November 2003 Internal T.I. 2003-0036737 F- BOURSES D'ETUDES-- summary under Subsection 56(3) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(3) $3,000 exemption unavailable where education tax credit not available in the same taxation year The Directorate indicated that post-secondary students who completed a program of study in August 2000 for which they received a scholarship in January 2001 could not benefit from the $3,000 deduction in computing the s. 56(3) scholarship exemption given that s. 56(3) only provided that the $3,000 exemption is available only if the scholarship or bursary is received by the taxpayer in connection with the taxpayer's enrolment in an educational program in respect of which an amount is deductible as an education tax credit in computing the taxpayer's tax payable for the year in which it is received. ...

19 December 2003 Internal T.I. 2003-0035347- AVAILABLE FOR USE RULES-- summary under Subsection 13(28) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(28) In connection with indicating that a building that was to be used as a sawmill which was substantially complete but was not yet operational (e.g., various items of processing equipment were still in crates) did not satisfy the test in s. 13(28)(a), the Agency stated: "In our view, the time 'all or substantially all' of the building is first used in the sawmill operation, will occur when 90% or more of the building's square footage is occupied by processing equipment that is also being used to process logs into lumber. ...

3 August 2004 Internal T.I. 2004-0077991I7 F- Allocations d'aide à domicile reçues de la SAAQ-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) CRA applies changes to its position as a result of taxpayer-friendly judgments effective to post-judgment assessments In connection with finding, in light of Maurice, 2001 DTC 3710, that car insurance proceeds received by the taxpayer to compensate her for her care services provided to her son, who had been rendered mentally unfit from a car accident, were accordingly to be treated as non-taxable, the Directorate stated: [CRA’s] usual policy on the scope of tax judgments that result in a change to a previous CRA interpretation or position that is beneficial to taxpayers is that the change applies in respect of all future assessments or reassessments. ...

28 February 2005 Internal T.I. 2004-0103991I7 F- Remboursement de frais de scolarité-- summary under Paragraph 56(1)(n) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) agreement of employer to pay tuition would have been taxable under s. 6(3) if a benefit The taxpayer, who had been employed as a temporary lecturer at a University Department, was hired to work as a professor at the Department upon her completion of doctoral studies at a US university and was paid by the Department various of the expenses incurred by her in connection with such studies including the tuition fees of the US university. ...

After referring to Yonge-Eglinton and before finding that the resulting costs would be deductible under s. 20(1)(e)(ii), the Directorate stated: [A]n expense is incurred in the course of a borrowing if it is in connection with, results from or arises from the manner of carrying out or the things that must be done to make the borrowing. ...

30 September 2002 Internal T.I. 2002-0152107 F- BRANCHEMENT A DES SERVICES PUBLICS-- summary under Subparagraph 8(1)(c)(iii) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(c)- Subparagraph 8(1)(c)(iii) utilities do not extend to cable, satellite TV and internet in light of s. 8(1) preamble Regarding the exclusion for “utilities,” the Directorate stated: [C]able television services, satellite television services and internet connection services are generally not relevant to the income from employment of a member of the clergy. ...

19 May 2020 Internal T.I. 2020-0841791I7- Application of paragraph 111(4)(e)-- summary under Paragraph 13(34)(a) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(34)- Paragraph 13(34)(a) goodwill and customer relationship constituted single goodwill property In connection with an acquisition of its control, Canco used a s. 111(4)(c) and(d) write-down of debt owing by a controlled foreign affiliate to designate the s. 111(4)(e) write-up of the capital cost of goodwill (Class 14.1), customer relationships (Class 14.1) and intellectual property (Class 12 – e.g., software or video copyright?). ...

18 February 2022 Internal T.I. 2020-0836351I7- 212(1)(d)/Copyrights/Trademarks/XXXXXXXXXX-- summary under Paragraph 212(1)(d) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d) royalties used outside Canada generally were subject to s. 212(1)(d) Royalties were payable by Canco to a non-resident for the right to use copyright and trademarks in connection with the design, manufacturing and sale of products in countries in a particular region. ...