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CRA responded: [A] person is considered to be living separate and apart from an individual… if the person lives separate and apart from the individual at that time because of a breakdown in their marriage or common-law relationship for a period of at least 90 days that includes that time. ...

Its fermentation tanks and barrels were considered to likely qualify for class 29 purposes as property used primarily in the manufacturing or processing of goods for sale. ...

Its fermentation tanks and barrels were considered to likely qualify for class 29 purposes as property used primarily in the manufacturing or processing of goods for sale. ...

Should the subsidiary be considered to have agreed to issue or sell the shares for purposes of s. 7, and would s. 7(3)(v) preclude a deduction by the subsidiary. ...

Would this transfer by X be considered to be for settlement of rights arising out of the marriage of X and Y for the purposes of s. 73(1.01)(b)? ...

CRA stated: In order for the disclosure to be considered complete…the taxpayer must provide complete and exact information and documents for all taxation years…for which there are inexact, incomplete or undisclosed particulars. ...

CRA responded: [T]he employee's motor vehicle trips in a day to go from her residence to the home of her first client and from the home of her last client to her residence may be considered as travel in the performance of the duties of an office or employment, provided that the homes of her clients do not constitute, for the employee, a regular place of employment. ...

Where the location from which the business is actually directed and administered is located on a reserve, the employer will generally be considered to reside on that reserve. … In order to determine the place where an Indian lives, we usually analyze whether the Indian lives on a reserve, in a domestic establishment that is his or her main place of residence and the center of his or her daily activities. ...

12 January 2015 Internal T.I. 2014-0560421I7- FX losses on CFA wind-up-- summary under Subsection 40(3.6) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.6) s. 40(3.6) not specifically ousted on s. 88(3) winding-up – but no affiliation after disposition In 2014-0538591I7, the Directorate indicated that s. 40(3.6) did not apply to deny a loss realized on the winding-up of a controlled foreign affiliate because (1) s. 69(5)(d) specifically ousts the application of s. 40(3.6) respecting property (the CFA's shares) disposed of on a winding-up, and (2) it is unlikely that under the foreign corporate law the CFA would be considered to still exist immediately after that disposition. ...

. … When the duration of a posting at a particular place of employment is not clearly indicated at the outset by the employee and the employer and that period actually lasts more than two years, it is generally considered that the work has never been of a temporary nature. … Where the employee and the employer do not clearly indicate the length of a posting at a particular work location, the intention of the parties to the effect that the assignment is temporary should be clearly demonstrated by other means to determine whether subsection 6(6) applies to the situation. ...