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In finding that, by virtue of s. 143.2(15), the individual’s 2016 taxation year could be reassessed beyond the normal reassessment period to deny the carried-back loss, the Directorate stated that “such carryback is closely linked to an adjustment in connection with a tax shelter investment and is necessary and required for the purposes of section 143.2.” ...

.-- 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 legal fees incurred in unsuccessful attempt to maintain child support were deductible Legal fees were incurred by Madame in connection with an application made by Monsieur to reduce the amount of child support payable by him under a judgment. ...

CRA responded: After noting that the third criterion in the Guidelines was that “the duties of the employment are in connection with the employer's non-commercial activities carried on exclusively for the benefit of Indians who for the most part live on reserves,” CRA stated: [I]t is the non-commercial activities of the employer, not the employment duties, that should be directed exclusively for the benefit of Indians who, for the most part, live on reserves. ...

Although the “because of” or “in relation to” test of related transactions does not require a strong nexus, it does require more than a mere possibility or a connection with an extreme degree of remoteness. ...

A, the Directorate first noted that “For this provision to apply, the CRA must establish that the disposition of Class "F" shares of the capital stock of Opco … was part of the series of transactions or events in which Opco acquired the Class "AA" shares of its capital stock for consideration less than their fair market value,” and then stated: Although the “because of” or “in relation to” test [in Copthorne] of related transactions does not require a strong nexus, it does require more than a mere possibility or a connection with an extreme degree of remoteness. ...

Therefore, there is a causal connection between the foreign tax paid and the adjustment to claim the foreign tax credit, regardless of whether the adjustment includes an addition to income under the provisions of section 110.5. ...

Therefore, there is a causal connection between the foreign tax paid and the adjustment to claim the foreign tax credit, regardless of whether the adjustment includes an addition to income under the provisions of section 110.5. ...

In addition, you informed us that the Equipment used by a non-resident corporation in connection with the performances by an artist were considered by the TSO to be of sufficient importance to constitute a permanent establishment for the purposes of Reg. 400(2)(e) at each of the venues where it mounted performances. ...

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. ...

This forward transaction was subsequently closed out by the taxpayer in connection with its sale of the Corporation 2 shares and use of the proceeds to repay the loan and pay a cash Maturity Payment to the Purchaser based in part on the appreciation in the shares’ value. ...