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However, where a similar benefit is offered by the corporation to all of its employees, including those who are also shareholders, the latter are usually considered to have received a benefit by reason of their employment. ...

Respecting a proposal that such recapture be prorated between active business income and property income based on the respective periods of time that the property generated the two types of income, the Directorate stated: [T]he CRA's position is that any recapture of capital cost allowance on the disposition of the building would also be considered to be active business income. ...

In your situation, the syndicate would therefore be considered to have paid to you the amount of $7,000 in payment as your share of the rental income, which should be included in your income as such, regardless of whether or not that amount was paid to you. ...

. … [T]he following should be considered in particular: the use that is actually made of the property in the course of the various activities of the FA, the income from the use or possession of the property, the intention of the FA with respect to the use and holding of the property, the terms and conditions of ownership of the property, the nature of the activities of the FA and current practices in the particular industrial sector. ...

Thus … a corporation that carries on a PSB will be able to deduct the salaries of the two trucker spouses if the two trucker spouses are considered to be incorporated employees of the corporation. ...

Respecting options with FMV exercise prices granted by the corporate employer which expire on a pro-rata basis over a five-year period, and which are exercisable upon the corporation subsequently notifying of its decision on the number of options that each employee may exercise, the Directorate stated: [A]n agreement to issue shares… would be considered to arise only at the time the notice is sent by the corporation to the employee and only in respect of the number of shares set out in the notice. ...

CRA considered a trust established by a CCPC to acquire and hold shares of the corporation for employees, with allocations among the employees and distributions entirely at the discretion of the trustees. ...

If…the taxpayer carries on two separate businesses…the income from the processing activity cannot be computed in accordance with the cash method of accounting provided for in section 28, and the processed meat cannot be considered as goods included in inventory in connection with a farming business. ...

Thus, before deciding whether to agree to be bound by a counter-letter, the CRA should consider all the facts, including whether the party wishing to transfer its interest has acted as a beneficial co-owner or whether the transferee should be considered to be the sole owner since the original acquisition date. ...

Thus, if you purchase an immovable with the intention of reselling it at a profit within a few years, the gain from the disposition of the immovable will generally be considered to be income from a business. ...