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In connection with this use, the purpose test will be met if the borrowed money replaces capital (contributed capital or accumulated profits) that was being used for eligible purposes that would have qualified for interest deductibility had the capital been borrowed money. 1.49 Contributed capital generally refers to funds provided by a corporation’s shareholders to commence, or otherwise further, the carrying on of its business. ... In connection with this use, the purpose test will be met if the borrowed money replaces accumulated profits of a corporation that have been retained and used for eligible purposes. ... The nature of the security provided in connection with borrowed money, or an amount payable for property acquired, has no impact on the tests for interest deductibility. ...

Please note that you may hear a beep and experience a normal connection delay). ... However, you have to include lump sum amounts that represent contributions you made to another RRSP during the 89 day period just before your withdrawal, and that were transferred to the RRSP indicated on line 1; the excess amount that you withdrew from your RRSPs in connection with the certification of a provisional past service pension adjustment, that you re contributed to this RRSP in the 89 day period just before your withdrawal, and for which you claim or will claim a deduction; an amount you contributed to this RRSP that was refunded to you as an unused amount (if you have filled out); or amounts you contributed as a repayment or cancellation payment to your RRSP under the Home Buyers’ Plan. ... However, you have to include lump sum amounts that represent contributions that your spouse or common law partner made to another RRSP during the 89 day period just before your spouse’s or common law partner’s withdrawal, and that he or she transferred to the RRSP indicated on line 5; the excess amount that your spouse or common law partner withdrew from their RRSPs in connection with the certification of a provisional past service pension adjustment, that your spouse or common law partner re contributed to this RRSP in the 89 day period just before their withdrawal, and for which your spouse or common law partner claims or will claim a deduction; an amount you or your spouse or common law partner contributed to this RRSP that was refunded to you or your spouse or common law partner as an unused amount (if you or your spouse or common law partner have filled out); or amounts your spouse or common law partner contributed as a repayment or cancellation payment to their RRSP or PRPP or both under the Home Buyers’ Plan. ...

Commercial activity also includes a supply of real property, other than an exempt supply, made by any person, whether or not there is a reasonable expectation of profit, and anything done in the course of making the supply or in connection with the making of the supply. ... Exclusively, for the purposes of related convention supplies, means property or services used all or substantially all (90% or more) in connection with a convention. ... Related convention supplies are property or services bought exclusively for consumption, use, or supply in connection with a convention. ...

A “mobile home” is defined to be: a building, the manufacture and assembly of which is completed or substantially completed, that is equipped with complete plumbing, electrical and heating facilities and that is designed to be moved to a site for installation on a foundation and connection to service facilities and to be occupied as a place of residence, but does not include any travel trailer, motor home, camping trailer or other vehicle or trailer designed for recreational use. ... Prior to April 24, 1996, a mobile home was a unit that was: Criteria not less than three metres wide and eight metres long; equipped with complete plumbing, electrical and heating facilities; designed to be towed on its own chassis on wheels to a site for installation on a foundation and connection to service facilities at that site; and to be occupied for residential purposes (year round occupancy was not necessarily required). ...

Please note that you may hear a beep and experience a normal connection delay. ...

When an individual moves from their home country to Canada for a temporary work assignment and continues to participate in an employer-sponsored pension plan in their home country in connection with their employment, the CRA will treat contributions made by or on behalf of the individual to the pension plan the same way for tax purposes as contributions made to a Canadian registered pension plan (RPP) if there is a provision in the tax treaty that allows foreign pension plans to be recognized. ... Where an individual moves from their home country to Canada for a temporary work assignment and continues to participate in a social security arrangement in the home country in connection with their employment, the CRA will treat contributions made by or on behalf of the individual to a social security arrangement Footnote 5 the same way for tax purposes as contributions made to the Canada Pension Plan (CPP) or the Quebec Pension Plan (QPP) Footnote 6 if there is a provision in the tax treaty that allows social security arrangements to be recognized. ...

" Act " means the Excise Tax Act as amended by Bill C-62; " business " includes a profession, calling, trade, manufacture or undertaking of any kind whatever, whether the activity or undertaking is engaged in for profit, and any activity engaged in on a regular or continuous basis that involves the supply of property by way of lease, licence or similar arrangement, but does not include an office or employment; " Canada " i) "Canada" includes (a) the sea bed and subsoil of the submarine areas adjacent to the coasts of Canada in respect of which the government of Canada or of a province may grant a right, licence or privilege to explore for or exploit any minerals; and (b) the seas and airspace above the submarine areas referred to in paragraph (i) in respect of any activities carried on in connection with the exploration for or exploitation of minerals. ii) In respect of imports, "Canada" has the meaning assigned by the Customs Act; " commercial activity " means: (a) any business carried on by a person; (b) any adventure or concern of a person in the nature of trade; and (c) any activity engaged in by a person that involves the supply of real property or of a right or interest in respect of real property by that person; but does not include: (d) any activity engaged in by a person to the extent that it involves the making of an exempt supply by the person; (e) any activity engaged in by an individual without a reasonable expectation of profit; or (f) the performance of any duty or activity in relation to an office or employment; " Department " means the Department of National Revenue, Customs and Excise; " Deputy Minister " means the Deputy Minister of National Revenue for Customs and Excise; " excisable goods " means any goods on which a duty of excise is imposed under the Excise Act or would be imposed under that Act if the goods were manufactured or produced in Canada; " goods " has the same meaning as in the Customs Act; " import " means import into Canada; " input tax credit " means a credit claimed by a registrant for the Goods and Services Tax paid or payable on any property or service consumed, used or supplied in the course of a commercial activity; " Minister " means the Minister of National Revenue; " non-resident " means not resident in Canada; " officer ", for purposes of section 216 of the Act and any provision of the Customs Act applicable by reason of section 216 in respect of the administration of Division III of Part IX of the Act, means an officer within the meaning of section 2 of the Customs Act and includes an officer employed in the administration of Part IX of the Act; " person " means an individual, partnership, corporation, trust or estate, or a body that is a society, union, club, association, commission or other organization of any kind; " personal property " means property that is not real property; " prescribed " means (a) in the case of a form, the information to be given on a form or the manner of filing a form, prescribed by the Minister, and (b) in any other case, prescribed by regulation or determined in accordance with the rules prescribed by regulation; " property " means any property, whether real or personal, movable or immovable, tangible or intangible, corporeal or incorporeal, and includes a right or interest of any kind, a share and a chose in action, but does not include money; " recipient ", in respect of a supply, means the person who pays or agrees to pay consideration for the supply or, if no consideration is or is to be paid for the supply, the person to whom the supply is made; " registrant " means a person who is registered, or who is required to apply to be registered, under sections 240 and 241 of the Excise Tax Act; " release " has the same meaning as in the Customs Act; " service " means anything other than (a) property, (b) money, and (c) anything that is supplied to an employer by a person who is or agrees to become an officer or employee of the employer in the course of or in relation to the office or employment of that person; " small supplier ", at any time, means a person who is at that time a small supplier under section 148 of the Excise Tax Act; " supplier ", in respect of a supply, means the person making the supply; " supply " means, subject to sections 133 and 134 of the Excise Tax Ac t, the provision of property or a service in any manner, including sale, transfer, barter, exchange, licence, rental, lease, gift or disposition; " tax " means the Goods and Services Tax payable under Part IX of the Excise Tax Act; " taxable supply " means a supply that is made in the course of a commercial activity but does not include an exempt supply; " zero-rated supply " means a supply included in Schedule VI to the Excise Tax Act. ... Regulations made under subsection 215(2) of the Act will provide for the following special valuation circumstances in connection with the imposition of the GST: (a) Temporary importations of goods enumerated in the following items contained in the Schedule to the Temporary Importations Regulations under the Customs Tariff (for a description of these items, refer to the Temporary Importations Regulations found in Customs Memorandum D8-1-1, Temporary Importations Regulations) will be subject to the GST on 1/60th of the value for duty for each month or part thereof that the item remains in Canada, plus any unremitted customs duty payable: (i) Items 4, 10, 13, 19, 28, 29, 34, 45 and 48 when imported by a non-resident; and (ii) Items 19, 22, 25, 37, 50, 51, 55 and 56 when imported by a resident or non-resident. ...

A “mobile home” is defined to be: a building, the manufacture and assembly of which is completed or substantially completed, that is equipped with complete plumbing, electrical and heating facilities and that is designed to be moved to a site for installation on a foundation and connection to service facilities and to be occupied as a place of residence, but does not include any travel trailer, motor home, camping trailer or other vehicle or trailer designed for recreational use. ... Prior to April 24, 1996, a mobile home was a unit that was: Criteria not less than three metres wide and eight metres long; equipped with complete plumbing, electrical and heating facilities; designed to be towed on its own chassis on wheels to a site for installation on a foundation and connection to service facilities at that site; and to be occupied for residential purposes (year round occupancy was not necessarily required). ...

However, these sections now appear in the Table of contents for easy access; the statement that folios are only available in electronic format has been moved to the end of the Application section; and the words “as promulgated under the Act” in connection with the Income Tax Regulations have been removed from the Application section, in the interest of using plain language. ... The treatment of expenses related to the operation of devices listed in paragraph 118.2(2)(i) are now discussed in ¶1.74, as the comments apply to operating costs for all devices listed in paragraph 118.2(2)(i). ¶1.81 (formerly ¶45 of IT-519R2) is expanded to provide the CRA’s view on the treatment of the costs of climate controlled storage space for the artificial kidney machine or supplies for the machine. ¶1.87 (formerly ¶49 of IT-519R2) is expanded to clarify the meaning of the phrase other products for purposes of paragraph 118.2(2)(i.1). ¶1.88 is added to refer readers to the discussion of subparagraph 118.2(2)(n)(i) to determine whether medical ointments used by a person in connection with products described in paragraph 118.2(2)(i.1), may be eligible medical expenses. ¶1.90 (formerly ¶51 of IT-519R2) is expanded to clarify that the cost of insulin, oxygen, liver extract injectible for pernicious anaemia or vitamin B12 for pernicious anaemia that are prescribed by a medical practitioner are also eligible medical expense under paragraph 118.2(2)(k). ¶1.91 is added to clarify that paragraph 118.2(2)(k) only covers the cost of insulin for persons with diabetes, but other costs incurred by these persons may be eligible medical expenses under other subsection of 118.2(2). ¶1.92 (formerly ¶52 of IT-519R2) is revised to refer readers to the CRA website for more information on expenses that may be eligible medical expenses under paragraph 118.2(2)(l). ¶1.93 (formerly ¶53) is revised to refer readers to the CRA website for information on calculating meal and vehicle expenses. ¶1.94 to 1.96 (formerly ¶54 of IT-519R2) are expanded to reflect a legislative amendment made by S.C. 2001, c. 17, s. 95(1) which added paragraph 118.2(2)(I.21) to the Act, effective for the 2000 and subsequent tax years, and a legislative amendment made by S.C. 2006, c. 4, s. 62(3), which replaced the existing paragraphs 118.2(2)(l.2) and (l.21) with new paragraphs effective for expenses incurred after February 22, 2005. ¶1.97 to 1.100 are added to provide additional guidance on the application of paragraphs 118.2(2)(l.2) and (l.21). ¶1.102 is added to reflect paragraph 118.2(2)(l.4) which was added to the Act by S.C. 1998, c. 19, s. 23(2), effective for the 1997 and subsequent tax years and the amendment to paragraph 118.2(2)(l.4) made by S.C. 2003, c. 15, s. 73(1), effective for the 2003 and subsequent tax years. ¶1.103 and ¶1.104 are added to reflect paragraph 118.2(2)(I.41) and (I.42) which were added to the Act by S.C. 2003, c. 15, s. 73(1), effective for the 2003 and subsequent tax years. ¶1.105 and ¶1.106 are added to reflect paragraphs 118.2(2)(I.43) and (I.44) and which were added to the Act by S.C. 2006, c. 4, s. 62(4), effective for the 2005 and subsequent tax years. ¶1.107 and ¶1.108 are added to reflect paragraphs 118.2(2)(I.5) and (I.6) which were added to the Act by S.C. 1998, c. 19, s. 23(2), effective for the 1997 and subsequent tax years. ¶1.109 to 1.112 are added to reflect paragraph 118.2(2)(I.7) which was added to the Act by S.C. 1998, c. 19, s. 23(2), effective for the 1997 and subsequent tax years. ¶1.113 and ¶1.114 are added to reflect paragraph 118.2(2)(I.8) which was added to the Act by S.C. 1999, c. 22, s. 34(2), effective for the 1998 and subsequent tax years. ¶1.115 and ¶1.116 are added to reflect paragraph 118.2(2)(I.9) which was added to the Act by S.C. 2000, c. 19, s. 25(4), effective for the 1999 and subsequent tax years. ¶1.117 is added to reflect paragraph 118.2(2)(I.91) which was added to the Act by S.C. 2000, c. 19, s. 25(4), effective for the 1999 and subsequent tax years. ¶1.119 to 1.121 are added to provide additional clarity. ¶1.122 (formerly the Appendix to IT-519R2) is revised to reflect a number of amendments that added paragraphs to the Regulation or amended existing paragraphs of the Regulation: paragraph 5700(c.3) was added by SOR/99-387, s. 1, applicable to the 1997 and subsequent tax years; paragraph 5700(w) was added by SOR/2001-4, applicable to the 1999 and subsequent tax years; paragraph 5700(w) was amended by SOR/2007-212, s. 3(3), applicable to the 2004 and subsequent tax years; paragraph 5700(i) was amended by SOR/2007-212, s. 3(1), applicable to expenses incurred for property acquired after February 22, 2005; paragraph 5700(l.1) was added by SOR/2007-212, s. 3(2), applicable to the 2005 and subsequent tax years; paragraphs 5700(x), (y), and (z) were added by SOR/2007-212, s. 3(4), applicable to the 2005 and subsequent tax years; paragraphs 5700(z.1), (z.2), (z.3), and (z.4) were added by 2009, c. 2, s. 109(1), applicable to the 2008 and subsequent tax years; and paragraph 5700(s.1) was added by 2012, c. 19, s. 18(1), applicable to expenses incurred after 2011. ...

All property held in connection with a PRPP is required to be held in trust by the administrator on behalf of the plan members. As a result, a PRPP is generally treated as a trust for tax purposes, the administrator is the trustee of that trust, the members are the beneficiaries, and the trust property is the property held in connection with the plan. ...