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Otherwise, the amounts could be considered social assistance and included in income under s. 56(1)(u). ...

Since in Scenario 2, the dividend would be considered received at the time when the shareholder was still a non-resident of Canada on the presumption (applying Banner Pharmacaps) that the note was issued and delivered to the shareholder in satisfaction of the obligation to pay the dividend, ss. 114 and s 90(1) would not apply to include such dividend in her income after immigration. ...

However, paragraph 6 of Article VII of the Treaty states that if an element of the business profits is dealt with separately in other provisions of the Treaty, then those provisions are to be considered. ...

. … Periods of absence from the workplaces abroad, in order to be included in the qualifying period, will generally have to be related to the contract with respect to the activities that are qualifying or consequential to the latter and the contract must be of a duration of more than six consecutive months in order for the employer to be considered to have carried on a business outside Canada for the purpose of the application of the OETC. ...

Thus, when that place is situated outside Canada, that person will not generally be considered as being an employee in Canada, and on that basis no source deductions are required to be made. ...

" After stating that "Parliament's specific requirement that an amount become owing after March 28, 2012, as set out in paragraph 15(2.11)(b), in order for the amount to qualify for PLOI treatment must be respected," CRA responded: [I]f a pre-March 28, 2012, debt is replaced with a newer debt of the same or substantially similar amount, the transactions may constitute a series of loans or other transactions as discussed in ¶ 28 of IT-119R4 … However, as discussed in ¶ 29 of IT-119R4... all of the relevant factors would need to be considered to determine whether a series of loans or other transactions and repayments existed and bona fide repayments would not be seen as part of a series of loans or other transactions and repayments. ...

In this context, the presence of extremely difficult situations, of financial hardship associated with extenuating circumstances, incorrect action or advice of officials of the Canada Revenue Agency, and unintended outcomes resulting from legislative provisions or other unusual circumstances have generally been considered in this determination. ...

In such a case, if it is shown that membership in a fitness centre allows the employee to meet the specific conditions that his or her employment requires, it may be, depending on the circumstances, that payment or reimbursement of membership in a fitness centre is considered principally for the advantage of the employer. ...

Consequently, the Intangible Expenditures will not be considered "eligible capital property," which is defined under s. 54 to mean property a part of the proceeds of disposition of which would qualify as an ECA. ...

10 March 2015 External T.I. 2014-0552551E5 F- Vente du droit d'exploiter une sablière-- summary under Qualified Farm or Fishing Property Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Farm or Fishing Property sale of rights to extract sand could be considered sale of qualified farm or fishing property A family farming partnership ("SENC"), which owns a "qualified farm or fishing property," sells the right to operate the sand pit to a municipality for a fixed sum. ...