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This portion must be an amount that can reasonably be considered to relate to the outstanding amount of the line of credit and not the available credit. … In the situation you described, if the NCPI is lower than the premiums payable, it does not seem reasonable to conclude that the total amount of the NCPI for the year would be deductible by virtue of paragraph 20(1)(e.2) in computing the income of the corporation. ...

. … [A] travel allowance provided for in a an arm's length new contract would not be considered a re-characterization of an existing salary…where: the old contract has legally ended; the legal rights and obligations under the new contract designate (on a prospective basis) a portion of an employee's hourly compensation as a travel allowance; … the travel allowance is accounted for separately in the payroll system and on the employee's pay stub; and the terms of the new contract are reflected in the collective agreement (where the employee is represented by a union). ...

28 April 2015 External T.I. 2015-0566011E5- Whether s. 16.1 applies to a transport truck-- summary under Subsection 16.1(1) Summary Under Tax Topics- Income Tax Act- Section 16.1- Subsection 16.1(1) identification of lease based on legal substance/no election for transport truck Before concluding that "since a transport truck would be considered exempt property, a lessee and a lessor would not be entitled to elect under section 16.1…[so that] the lessee would not be entitled to deduct CCA on this vehicle, " CRA stated: As noted in Income Tax Technical News ITTN No. 21, it is our view that the determination of whether a contract is a lease or a sale for income tax purposes is based on the legal relationships created by the terms of the particular agreement, rather than the underlying economic reality. ...

In response to a query as to whether the taxpayer could deduct all of the interest incurred in Year 2 on the basis that the debt related to a single large tract of land, CRA quoted its position at the 1989 Corporate Management Tax Conference Round Table, Q. 13, referred to 5-8343 and to Q. 39 at the 1991 annual CTF Roundtable, stated that the position in these pronouncements was still valid, and added (TaxIntepretations translation): [T]he revenues derived from the sale of the XXXXXXXXXX lots cannot be considered gross revenues derived from one or the other of the respective plots of land for purposes of paragraph 18(2)(e). ...

Otherwise, the amounts could be considered social assistance and included in income under s. 56(1)(u). ...

After noting a current GAAR review by Aggressive Tax Planning, the Directorate stated that LeCavalier " supports the application of GAAR… where the debt parking rules … were considered to have been misused or abused. ...

However, where after entering into the contract with Canco, USCoinstead subcontracts a portion of the work to a Canadian subsidiary of USCo or an arm's length Canadian company, USCo will not be considered to have a PE in Canada provided such Canadian company is paid an arm's length fee – and similarly, if a US professional firm subcontracts part of its consulting contract with Canco to an arm's length Canadian professional partnership. ...

Since in Scenario 2, the dividend would be considered received at the time when the shareholder was still a non-resident of Canada on the presumption (applying Banner Pharmacaps) that the note was issued and delivered to the shareholder in satisfaction of the obligation to pay the dividend, ss. 114 and s 90(1) would not apply to include such dividend in her income after immigration. ...

Accordingly…the Swap Contracts are considered to be inventory for the purposes of paragraph 85(1.1)(f). ...

After finding that the swaps qualified as "inventory" under the broad s. 248(1) definition and, therefore, as eligible property under s. 85(1.1)(f), the Directorate responded to the view of the TSO that "the election…was invalid," the Directorate stated: [T]he Taxpayer's derivatives could be considered as inventory for the purposes of subsection 85(1), which supports the Taxpayer's contention that XX intention was to record the transfer as inventory. ...