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Accordingly … only the taxable capital of the CCPC (Xco) should be considered for purposes of the proposed amendments to subsection 125(5.1) since the facts submitted indicate that the associated corporation (Yco) does not carry on business through a permanent establishment in Canada within the meaning of subsection 400(2) of the ITR. ...

The Directorate stated: Even though the definition “taxable dividend” applies for the purposes of the Act, the interest paid or credited under subsection 214(16) is deemed [under the s. 214(6) preamble] to have been paid as a dividend solely for the purposes of Part XIII and, accordingly, it is considered to be a “taxable dividend” solely for the purposes of Part XIII. ...

We consider that the impact on accumulated earnings of other non-arm's length transactions must be considered in light of the facts of each particular situation. ...

It is our view that amounts of $15 to $20 per day paid to volunteers to defray the cost of using a car or meals during volunteer activities, even to travel from home to work, would not be considered employment income if they are the only amounts received by them. … In addition, where a worker uses an automobile owned by the organization, not only for volunteer activities, but also for commuting to and from work, we are also of the view that this benefit does not give rise to tax consequences, provided that the cost of the automobile is reasonable and that it is the only personal use made of it. ...

(s. 871(m)) characterization, as a dividend, of a principal or derivative payment by a Canadian issuer to a Canadian investor, is irrelevant to T5 reporting What are the Canadian tax reporting requirements respecting a payment made under a Canadian financial contract (i.e. a contract between an entity resident in Canada and a Canadian-resident investor) that is considered “dividend equivalent amount” under new Code s. 871(m)? ...

CRA responded: Such renunciations could not be considered disclaimers for the purposes of the Act because they would be transfers of property from some of the intestate heirs (Children A) to Mrs. ...

CRA responded: Such renunciations could not be considered disclaimers for the purposes of the Act because they would be transfers of property from some of the intestate heirs (Children A) to Mrs. ...

The capital sum insured … can therefore be considered to be an amount of principal owed to the Corporation … on which the Court awarded interest under article 1619 C.C.Q. ...

In indicating that the shares of the two Holdcos qualified as shares of family farm corporations under the “Definition”, CRA stated: [A] corporation that is a member of a partnership would be considered to be carrying on the same business as that carried on by the partnership. ...

Consequently … the $XXXXXXXXXX received by Xco under the Agreement is considered a loan for the purposes of the Act and is not taxable. … In general, if paragraph 12(1)(x) is not applied at the time a loan was made, the loan would come within section 80 at the time it is settled or extinguished. ...