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However … where a “professional status” is only acknowledged in an organization’s bylaws, the “professional status” would not likely be considered “recognized by statute” …. ...

After noting that the members were “employees” by virtue of holding offices, that the members' constituency offices could be their ordinary place of employment, and that s. “6(1)(b)(vii) … specifically excludes from income reasonable travel allowances, namely all amounts received by an employee from the employer for travelling away from the municipality (and the metropolitan area, if there was one) where the employer’s establishment, at which the employee ordinarily worked, was located,” CRA stated: An allowance for accommodation expenses will not be considered reasonable … if it does not represent an estimate of the cost of accommodation that may be incurred by the employee during the travel that generated entitlement to the allowance. ...

A carry-forward period of up to six months would generally be considered reasonable and would not, in and of itself, disqualify the HCSA from being a PHSP. ...

Could limited partnership losses be considered in computing the adjusted stub period accrual (“ASPA”) of Opco? ...

The terms and conditions of the shared ownership arrangement, the specific life insurance contract and all other related agreements which may form part of the particular arrangement and the particular facts at the given time would have to be considered in the determination of the FMV of Opco’s interest in the life insurance policy. … The CRA does not have its own method for computing the FMV; this computation is based upon the facts known on the valuation date, to which the principles and standards of the Canadian Institute of Chartered Business Valuators are applied. ...

In 2017-0735771I7, Headquarters considered that such loss was suspended on the basis that, for purposes of s. 40(3.5)(c)(i), Bco was a corporation “formed” on the “merger” of CCo with BCo – with the result that BCo was deemed to continue to own the shares of CCo with which it was affiliated, notwithstanding that CCo had, in fact, ceased to exist. ...

If there was no such agreement, repayments would be considered to be made pro rata as between the forgivable and non-forgivable portion of the loan, thereby stretching out the s. 20(1)(hh) deductions. ...

28 October 2020 External T.I. 2019-0824091E5- Members of a credit union of the same class-- summary under Allocation in Proportion to Borrowing Summary Under Tax Topics- Income Tax Act- Section 137- Subsection 137(6)- Allocation in Proportion to Borrowing “class” determined in accordance with credit union’s incorporating statute Would payments made to members of one branch of a credit union be considered payments to “members of the credit union of the same class” for purposes of the definitions of “allocation in proportion to borrowing” and “bonus interest payment” in s. 137(6)? ...

After referring to the employee benefit plan (“EBP”) definition in s. 248(1), CRA noted: Generally, a plan will be considered to be a pension plan (irrespective of whether it is registered under the Act) “where contributions have been made to the plan by or on behalf of an employer or former employer of an employee in consideration for services rendered by the employee and the contributions are used to provide an annuity or other periodic payment on or after the employee’s retirement.” ...

The gift of the equitable interest in the CRT is considered to have been made to the qualified donee when the property is transferred to the CRT, provided that the equitable interest in the CRT vests with the qualified donee at that time (and all other requirements are met). … The GRE does not receive the equitable interest in the CRT in return for the transfer. … [T]he property received by the GRE on and as a consequence of the death of the individual is not substituted for or replaced by the equitable interest in the CRT received by the qualified donee. ...