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In finding that X and Y are related, CRA stated (TaxInterpretations translation): Paragraph 252(1)(c) expands the meaning of the term “child” by providing that the child of a spouse or common-law partner of a taxpayer is considered a child of the taxpayer…. ...

24 April 2015 External T.I. 2014-0560401E5- Subsections 15(2) and 227(6.1) and Part XIII tax-- summary under Subsection 227(6.1) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(6.1) repayment of assigned loan to assignee after 2 years In 2013-0482991E5, CRA considered that where Canco seeks to avoid the application of s. 15(2) to a loan (the "Debt") owing to it by a non-resident sister company (Debtco) by assigning the Debt to their non-resident parent (Parentoco) in repayment of a loan owing by it to Parentoco, this assignment will not qualify as a repayment of the Debt (so that s. 214(3)(a) could then apply to impose Part XIII tax on the Debt amount). ...

. … Based on the limited description…the digital currency would be held outside of Canada and would not be considered to be used or held exclusively in the course of carrying on an active business. ...

For example, some projects could be considered as the installation or improvement of a structure on the surface or sub-surface, the surface being the land or property. ...

…[T]he determination of the nature of the contractual relationship between the Employer and the Leasing Corporation is one of fact and law to be considered by the parties. ...

Consequently, LP would not be considered to be a "foreign affiliate" of Canco 3 and Forco's interest in LP would not qualify as "excluded property"…. ...

2 April 2014 External T.I. 2012-0473151E5 F- Limitation du coût de location d'un véhicule-- summary under Section 67.3 Summary Under Tax Topics- Income Tax Act- Section 67.3 GST ITCs included under element E of formula Are amounts of recovered GST and QST respecting the lease of a vehicle to be considered in element E in ss. 67.3(c) and (d)? ...

2 April 2014 External T.I. 2012-0473151E5 F- Limitation du coût de location d'un véhicule-- summary under Subsection 248(16) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(16) GST ITCs constitute a “reimbursement” for car lease expense limitation purposes Are amounts of recovered GST and QST respecting the lease of a vehicle to be considered “reimbursements” under element E in ss. 67.3(c) and (d)? ...

Would the Taxpayer and the Other Person can be considered common-law partners in Canada? ...

Would the Taxpayer be considered a resident of Canada given his close ties? ...