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The Directorate responded: In order to determine whether there is a connection for retiring allowance purposes, the courts have formulated the following two questions: 1. ...

After the taxpayer’s death, and in connection with a capital dividend account computation, the taxpayer’s representatives took the view that this amendment resulted in the policy’s disposition, so that the adjusted cost basis of the “new” policy only reflected the premiums that had been paid subsequently to the amendment. ...

It is important, however, to ensure that the purpose of subsections 56.1(2) and 60.1(2) is clearly reflected in the wording of those documents and, inter alia, that the recipient knowingly assumes a tax burden in connection with third-party payments made by the payer of expenses covered by subsections 56.1(2) and 60.1(2). ...

3 August 2004 Internal T.I. 2004-0077991I7 F- Allocations d'aide à domicile reçues de la SAAQ-- summary under Paragraph 3(a) Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a) insurance proceeds to compensate for parent’s home care services provided to disabled son were non-taxable 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: The present situation appears to us to be similar to that in Maurice, since Ms. ...

28 February 2005 Internal T.I. 2004-0103991I7 F- Remboursement de frais de scolarité-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment of tuition fees conditional on a return to extended employment was not a taxable 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. ...

Expense- Contract or Option Cancellation Target’s cash-cancellation of executives' options was on capital account The Directorate maintained its position in 2001-0098827 F that, consistent with Kaiser Petroleum and Canada Forgings, that cash amounts paid by a target (Bco) for the cancellation of employee stock options under a stock option plan (the “Plan”) in connection with Bco's privatization (so that Aco became Bco's 100% owner) were capital expenditures, notwithstanding that one executive chose to exercise the individual’s options in order to acquire shares of Bco. ...

The Directorate stated: [T]he term “reasonably attributable” … denotes … a direct causal connection … between the OCNP and the PE taking in account all the applicable facts of the case. … [Per] E9807035 … the taxpayer should attribute a portion of its gross revenues to each permanent establishment in recognition of the value of the ancillary services provided by that establishment. … [W]here a taxpayer has made an allocation under subsection 403(4) and the taxpayer’s approach is reasonable, the CRA should not require the taxpayer to use a different method of allocation. … [T]he allocation of the OCNP based on where the policies are underwritten … appears to be a reasonable method. ...

23 April 2019 Internal T.I. 2018-0750821I7 F- Revenu d’emploi d’un Indien-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 employee lease-out servicing activity does not give rise to exempt income if only connection to reserve is employer residence The employer is located on a reserve and carries on a construction business. ...

Audit may wish consider whether an adjustment to the amount deductible by Canco is warranted in the event that one or more of Canco’s employees changed employers within the Parentco group during the grant-to-vest period resulting in the PSP awards not being fully attributable to services rendered in connection with Canco’s business. ...

18 February 2022 Internal T.I. 2020-0836351I7- 212(1)(d)/Copyrights/Trademarks/XXXXXXXXXX-- summary under Subparagraph 212(1)(d)(vi) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(vi) onus on CRA to allocate between exempt and taxable royalties – but not bound by licence agreement allocation 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. ...