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CRA found that the regular blue-collar meal allowances satisfied the following tests and, thus, were not taxable: [T]he CRA does not consider a meal allowance paid to such an employee working overtime as income if the following criteria are satisfied: the value of the meal or meal allowance is reasonable: in general, an amount up to $17 will be considered reasonable; the employee works at least two hours of overtime immediately before or immediately following the employee's normal scheduled hours of work; the overtime is infrequent or occasional. ...

However, expenses that are related to the restoration of the building to its original state should be considered as current expenses. ...

However, if Subco were not merged with OPCO following the acquisition of the shares, other elements may have to be considered …. ...

For this purpose, a secondary residence consisting of a building and land, which would be a personal-use property and thus, for tax purposes, one and the same property, could be replaced by a new property, which would also consist of a building and land, and which would be considered as a single replacement property. … Second, the replacement property must have been acquired for the same or similar use as the former property. ...

After stating that it could be considered that “an expense is ‘incurred’…only where there is an obligation to pay a sum of money,” CRA went on to state: [I]f it is established that that the services are provided and the expenses are incurred in 2016, the expenses paid to a dentist for dental services would be medical expenses under paragraph 118.2(2)(a) as long as the expenses were paid at some time. ...

Since IFRS reporting is considered Canadian GAAP, it is appropriate to use “Total comprehensive income”, representing a combination of profit or loss and other comprehensive income (“OCI”), as a starting point for computing ANI/ANL [adjusted net income/adjusted net loss]. ...

CRA considered that s. 251(5)(b)(ii) would apply even where there was an automatic USA requirement on Opco to redeem shares of a defaulted shareholder (rather than only as required by the non-resident) because the non-resident would have the right to require Opco to do so if it did not fulfill its obligation to do so automatically. ...

Where the work on an addition to the main building begins in a taxation year and ends in the following taxation year, we are generally of the view that the taxpayer is considered to have acquired the addition at the end of the first taxation year and that subsection 1102(23) will apply at that time to deem the capital cost of the addition on that date to be a separate building. ...

CRA also indicated, similarly to 2016-0679751E5 F, that, in light inter alia of s. 248(8)(a), a payment could be considered to be made to a surviving spouse directly or indirectly out of the former TFSA as a consequence of the deceased’s death where an executor in his discretion chooses to satisfy a legacy of specific property (in this case, of the residue of the estate, which included the family residence) by retaining the proceeds from the sale of the residence and instead paying an equivalent amount out of TFSA property. ...

The "all or substantially all" test is considered to be met if 90% of the duties were performed abroad. ...