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4 June 2012 Interpretation Case No. 131194-- summary under Paragraph (l) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (l) taxable loan broker fees from car dealers The fees earned by a loan broker from car dealers would generally be considered predominantly administration services of obtaining credit information from purchaser, completing the loan application, explaining loan terms to purchaser, preparing contracts for the dealer, submitting the completed contracts to lending institutions, and would not be a financial service under paragraph (l) of the definition of financial service. ...

9 May 1990 Meeting (October 1990 Access Letter, ¶1474)-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) "If at the time of the 'butterfly' reorganization the shareholders had formed the intention to sell their shares, and their shares are eventually sold, the reorganization and the ultimate sale will be considered to form part of the same series even though at the time of the reorganization the shareholders either had not determined all of the important elements of the subsequent sale- such as, for example, the identity of the purchaser or the purchase price and terms of payment- or lacked the ability to implement the subsequent sale. ...

A car allowance generally (but not always) will be considered reasonable if it does not exceed the 27 cents/21 cents amount. ...

Where it is considered that a part of a debt is collectible and a part is not, a portion only of the debt may be viewed as a bad debt. ...

Transactions which are structured as management agreements or licences and under the terms of which a lessee/lessor relationship does not exist would not generally be considered as leases for income tax purposes. ...

. … For this reason, one is to assume that the expenses would need to be submitted to the insurance company before the amount can be considered by the Canada Revenue Agency…. ...

Round Table, Q. 34-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Transactions, whereby an individual took advantage of the fact that he had preferred shares of a holding company with a fair market value and ACB (of $400,000) corresponding to the safe income and fair market value of shares of an operating company, in order to effect a disposition of the shares of Opco to a third-party purchaser on a tax-free basis, were considered to represent an abuse given that former s. 247(1) would have applied to such transactions and given that if the holding company had sold its shares of the operating company directly, the individual would have realized the proceeds of disposition by way of a taxable dividend. ...

CRA also stated that if the grantor of a transfer payment (incluidng acontribution, subsidy, or similar payment) does not receive any property or service in return, then the payment is not consideration for a supply since there is no activity involved that can be considered to be a supply" ...

Round Table, Q. 12-- summary under Subsection 10(1) Summary Under Tax Topics- Income Tax Act- Section 10- Subsection 10(1) Where the taxpayer follows a method of averaging initial production costs over the forecast number of units to be produced, "if the initial production costs are considered an inventory cost or deferred costs for purposes of preparing the financial statements, the Department would not usually allow a deduction in the year in which the costs were incurred unless the method used to prepare the financial statement does not comply with generally accepted accounting principles or does not enable a fair presentation of profits or clear matching of goods and costs. ...

A will be considered for purposes of s. 69(1)(b)(ii) to have made a gift of part of his economic interest in the corporation to Mrs. ...