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An affiliated employer does not include a person who would not otherwise be related or considered affiliated with another person but for the definition of "person related to the employer" in section 60(j.1)(iv). ...

The Directorate stated: Since Parliament used the term "deducted" as opposed to "deductible" in paragraph 111(3)(a), we are of the view that any portion of the loss actually deducted by the Corporation in previous taxation years must be considered, even if the taxpayer deducted an amount in error [citing Dominion of Canada General Insurance]. ...

Therefore, book debts that have been reduced by outstanding cheques on the date of the end of a fiscal period cannot be considered to have been paid on that date for the purposes of the tax under Part I.3 of the Act. ...

For the purposes of Part XIII and s. 116, any amount paid or credited by a payer to the sub-custodians in respect of property held by a Sub-Fund on behalf of the New Investors, including purchase consideration for such property, will be considered an amount paid or credited to the New Investor in proportion to its co-ownership interest in the assets and Gross Income of the particular Sub-Fund. ...

Ruling ForCo will not be considered to be carrying on business through a permanent establishment, as defined in Art. ...

The CRA generally takes the position that supplementary pension benefits will be considered reasonable if: the terms of the plan are substantially the same as those of the RPP that applies to the same beneficiaries to whom the plan applies; and the benefits that can be paid under the plan are the same as the benefits that would have been paid under the RPP but for the defined benefit or money purchase limit. … [T]he basic contribution component of the Supplemental Plan appears to be largely consistent with the CRA’s general position outlined above. … However, the bonus contribution and vacation pay contribution components of the Supplemental Plan, as well as the Retirement Allowance Plan, appear to be primarily motivated by tax deferral considerations …[and] would most likely constitute an SDA. ...

For the purposes of Part XIII and s. 116, any amount paid by a person to the Sub-custodian respecting Sub-fund Canadian securities will be considered to arise at the time of payment and to have the same character and source in respect of each Unitholder thereunder in proportion to the number of Units held by that Unitholder that represents its participation in such property. ...

. … [A] plan that otherwise meets all of the conditions in paragraph 3 of … IT-339R2 … is considered a PHSP as long as all of the expenses covered under the plan are medical or hospital expenses (“medical expenses”) or expenses incurred in connection with and within a reasonable time period following a medical expense, and all or substantially all (generally 90% or more) of the premiums paid under the plan relate to the coverage of medical expenses that are eligible for the medical expense tax credit (“METC”). ...

As a result, the Participant would be considered to have received an amount equal to the fair market value (FMV) of the Participant’s units and be required to include that amount in income from employment in the year in which the disposition occurs. ...

Headquarters indicated that such dividend was subject to Part IV tax in the hands of Holdco because the time at which it was considered to have received the s. 104(19) dividend (the calendar year end of the Trust) was in the taxation year of Holdco (commencing on July 1, 2017) throughout which Opco was no longer connected to Holdco. ...