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28 October 2002 External T.I. 2002-0117595 F- REVENU EXPERT-COMPTABLE-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income accountants required to individually recognize professional income earned by them as employees of an NPO corporation In the context of a non-profit association employing chartered accountants who provide accounting and tax services to the association’s members, but with the chartered accountants billing such members for their services directly (as required by the provincial professional body) and paying over the proceeds to the association, CCRA applied its position in IT-189R2, para. 2 that if provincial law or the regulatory body for the profession precludes the practice of the profession by a corporation, income derived from the profession will normally be considered to be earned by the individual who rendered such professional services and not by a corporation – so that such billings were required to be included in the chartered accountants’ business income, but with a deduction for the value of the administrative services provided to them by the association. ...

CCRA considered it unlikely that the rental income should be regarded as pertaining to or incident to that business, stating: [T]here does not appear to be a close link between the operation of the business and the rental of the excess space. ...

If no longer having the asset would destabilize the corporation's operations, the asset would generally be considered to be used in the course of a corporation's operations. … [The] corporation's assets, particularly cash and longer-term investments, would require that type of analysis. ...

CRA ruled that the FCP including the constituent sub-funds would be treated as fiscally transparent for purposes of the Act so that, for example, dividends or interest paid by a particular Canadian investment in a sub-fund would be considered an amount paid directly to the unitholder “in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund.” ...

6 March 1995 Internal T.I. 9409947- WINDING-UP OF A FOREIGN AFFILIATE-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition no disposition of shares of UK sub on interim liquidation distributions In finding that the shares of a UK subsidiary were disposed of when the shares were cancelled on completion of voluntary dissolution proceedings CRA stated: [I]t would be inconsistent with the spirit of the law to consider the disposition of the shares of a controlled foreign affiliate to have occurred as soon as the shareholders become eligible for partial proceeds of disposition on a wind-up because not only is it impossible to compute the full amount of the gain at that time, any FAPI that may be earned by the affiliate subsequent to that time presumably could not be considered to be in respect of shares owned by the taxpayer for the purposes of subsection 91.... ...

CRA responded: When the creditor receives a payment on account of the outstanding principal amount of a debt obligation, the creditor is considered to have disposed of a portion of that obligation with the amount of the payment constituting the proceeds of disposition of that portion. ...

4 December 2018 External T.I. 2016-0670851E5- Regular Places of Employment and Personal Travel-- summary under Subparagraph 6(6)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(6)- Paragraph 6(6)(b)- Subparagraph 6(6)(b)(i) travel between temporary place of residence and special work site not excluded In the course of a general discussion as to when a particular work location is considered a regular place of employment (RPE) for an employee, CRA stated: [T]he value of a reasonable employer-provided allowance or reimbursement for travel between an employee’s principal place of residence and a special work site is excluded from the employee’s income, regardless of whether the special work site is a RPE for the employee. ...

The taxpayer’s list of uncertain tax positions that relates to the tax reserves in the taxpayer’s financial statements is considered to be part of the taxpayer’s books and records and is not a privileged document unless otherwise demonstrated. ...

27 November 2018 CTF Roundtable Q. 2, 2018-0780071C6- Impact of 55(2) deeming rules-- summary under Subsection 52(2) Summary Under Tax Topics- Income Tax Act- Section 52- Subsection 52(2) property dividended has cost equal to FMV where subject to s. 55(2) CRA indicated that where a dividend in kind paid by a corporation is subject to s. 55(2), the dividend recipient will be considered to have acquired the distributed property at a cost under s. 52(2) equal to its fair market value. ...

Before finding that these amounts were taxable under s. 6(1)(b), CRA stated: [T]he use of a personal cellular phone, bus washing, and electricity consumption would be considered an allowance because the employees are not required to submit receipts to receive the payments from the employer. ...