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Since the debt was non-interest bearing and did not provide for any other form of return, and the debt arose from the disposition of options received in the course of an office or employment, the loss in question will not be considered to be a loss eligible for any deduction based on the debt having been acquired for the purpose of gaining or producing income from a business or property. ...

The Directorate went on to indicate that s. 105(2) could apply “to all or part of the expenses actually incurred by Opco that could reasonably be considered to be attributable to the portion of the Immovable occupied by Sister as a place of residence” and that any “portion of the amount that would be included under subsection 105(2) in computing Sister's income may be deducted in computing the trust's income pursuant to paragraph 104(6)(b).” ...

Thus … a corporation with no assets or liabilities at the end of a taxation year (or a corporation with no liabilities at that time) cannot generally be considered insolvent for the purposes of subparagraph 50(1)(b)(iii). ...

Since for the purposes of the Act an estate is considered to be a trust, the estate may therefore acquire an annuity as annuitant as long as the minor child is the only one, prior to their death, beneficially interested in the amounts payable under the annuity. ...

In each case, would such land be considered to be an asset used principally in an active business “carried on” by the corporation for purposes of the definition of "qualified small business corporation share"? ...

The transaction was therefore not a speculative transaction and cannot be considered as an adventure in the nature of trade. ...

On the other hand, income from property that is employed or risked in a corporation's business operations is considered to be active business income. … [T]he Court's judgment had the effect of crystallizing the amount receivable and making it payable to the Taxpayer retroactively from the date of the summons. ...

In the course of a general discussion of a scenario in which, because of the remoteness of certain customers, the employer would pay $30.00 per day worked in situations where employees could not return home within 36 hours, CCRA indicated that: The phrase "the duties performed by the taxpayer were of a temporary nature” was considered to refer to the duration of the work performed by the employee in question and not to the expected duration of the project undertaken by the employer. ...

In finding that Opco’s safe income on hand at the safe income determination time (June 29) should be reduced by the s. 111(5.1) write-down, CCRA referred to the statement in the 1988 Robert Read paper that: If it is reasonable to expect that any of the income earned or realized in a stub period will be offset by losses in the remainder of the year, then the calculation of the safe income on hand for the stub period should reflect the anticipated losses, since that income could not reasonably be considered to be reflected in the inherent gain in the shares. ...

“[I]f an employee voluntarily adheres to the telework arrangement proposed by their employer, the employee is considered to have an obligation to use part of their home to perform the duties of employment and to pay certain expenses relating to this space devoted to working from home as long as the employee and the employer enter into a formal telework agreement.” ...