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An organization, professional or otherwise, that provides evaluation, examination, or other such services, but does not provide educational courses, is not considered to be an educational institution for purposes of paragraph 118.5(1)(a); c) An educational institution is not ineligible under subparagraph 118.5(1)(a)(i) solely by reason of the fact that it provides other courses in addition to post‑secondary school level courses; or d) An institution in Canada that has been designated as a specified educational institution under the Canada Student Loans Act or that has been recognized for the purposes of the Canada Student Financial Assistance Act or An Act respecting financial assistance for education expenses of the Province of Quebec is presumed to satisfy the eligibility requirements. ...

.]… 1.59 Where control of a corporation is acquired and that corporation makes a designation under paragraph 111(4)(e) to realize an accrued foreign exchange gain on a foreign currency denominated debt that arises because of the application of subsection 111(12), the new corporation formed on a subsequent qualifying amalgamation of that corporation would, under paragraph 87(7)(d) and for the purposes of subsections 40(10) and (11), be considered to be the corporation that realized the gain in respect of the foreign currency denominated debt under paragraph 111(4)(e) and subsection 111(12). ...

The taxpayer's income or loss from the partnership for the fiscal period ending October 31, 2015 would be determined in Canadian currency then, pursuant to paragraph 261(5)(c), would be converted to the electing taxpayer's elected functional currency based on the days the relevant amounts are considered to arise. ...

(The payment also is not a contribution.) 3.13 However, in connection with a promotional contest, a cash prize paid directly to the winner’s plan would be covered by the (a)(v) exception, but would be a contribution "because such cash prizes are not considered a return on investment. ...

CRA also states that the payments “do not constitute a premium, gift, or contribution to the plan (as they are considered a return on investment).” 3.36-3.37 [dealer reimbursement for deferred redemption charge] Where in order to encourage an investor to switch from another mutual fund company, a dealer will reimburse for any deferred sales charge incurred on the sale of the old funds, the payment of the rebate into the plan will not constitute a premium, gift or contribution to the plan – and will also not constitute an advantage, provided that the rebate is determined in a normal investment context without regard to the tax attributes of the individual’s registered and non-registered account(s). ...

S3-F3-C1- Replacement Property-- summary under Paragraph 44(5)(a.1) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(a.1) Similar use test based on similar business test and same physical type 1.38 Where the former property was used for the purpose of gaining or producing income from a business, another property will usually be considered to be a property acquired for the same or a similar use if it is acquired to gain or produce income from the same or a similar business and if it generally bears the same physical description as the former property. ...

[A] fine or penalty incurred in relation to a transaction that is outside the scope of a taxpayer's normal business activities should not be included in the computation of profit from that business for purposes of subsection 9(1).... 1.13 However, in determining whether profit is correctly computed for purposes of subsection 9(1), the Federal Court of Appeal clarified in Canadian Imperial Bank of Commerce that questions relating to the morality of a taxpayer's conduct will not be relevant. 1.16 Based largely on case law, the CRA will not consider the following factors to be relevant in determining whether a fine or penalty was incurred by a taxpayer for the purpose of gaining or producing income from the business or property: whether the taxpayer attempted to prevent the act or omission that gave rise to the fine or penalty; whether the taxpayer's income-earning purpose was achieved through the act or omission that gave rise to the fine or penalty; whether the fine or penalty was avoidable; whether it would be contrary to public policy to allow the taxpayer to deduct the fine or penalty in the circumstances; or whether the taxpayer's conduct that gave rise to the fine or penalty could be considered egregious or repulsive. ...

S4-F2-C1- Deductibility of Fines and Penalties-- summary under Subsection 18(9.1) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(9.1) Computing the deemed interest amount 1.34 For tax purposes, an amount deemed to have been paid as interest under paragraph 18(9.1)(e) will be considered interest for tax years ending after the rate reduction fee or prepayment penalty is paid (such tax years are referred to below as future tax year(s)). ...

Regardless of any contrary provisions in the trust agreement, the actions of these other persons in respect of the trust must be considered. 1.6 …[R]elevant factor[s] … may include: the factual role of a trustee and other persons with respect to the trust property, including any decision-making limitations imposed thereon, either directly or indirectly, by any beneficiary, settlor or other relevant person; and the ability of a trustee and other persons to select and instruct trust advisors with respect to the overall management of the trust. ...

S3-F9-C1- Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) Accumulated vacation and sick leave credits 1.6 Payments in respect of accumulated vacation leave and sick leave are considered to be income from an office or employment and taxable under subsection 5(1) in the year in which the payment is received. ...