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Several strict conditions must be satisfied in order for such trusts to be considered excluded foreign property. ...

Furthermore, the corporation is not considered to have received this credit until it has submitted the prescribed documents and information, it is shown that the corporation is entitled to the credit and it is applied as a payment of tax due by the corporation or at the time the credit is actually paid. ...

28 April 2010 External T.I. 2009-0347581E5 F- Frais de formation-- summary under Subsection 20(10) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(10) convention expenses providing an enduring benefit may be deducted within the s. 20(10) limitations When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of operating a business or an immovable are deductible, CRA stated: Training costs are not deductible as current expenses and are considered to be capital expenditures under paragraph 18(1)(b) if the training course to which they relate provides a lasting benefit to the taxpayer. … As stated in paragraph 9 of IT-357R2, a training course should be distinguished from a convention. ...

CRA responded: For the purposes of the Act, two spouses who are living separate and apart due to a breakdown of their relationship without a divorce judgment having been granted are still considered to be spouses. ...

28 June 2010 External T.I. 2010-0357081E5 F- Crédit d'impôt pour la rénovation domiciliaire-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense home renovation expenses generally considered to be incurred by the individual even where reimbursed by insurance company Can a qualifying expenditures incurred by an individual qualify as being incurred for home renovation tax credit purposes if a portion of those expenses are reimbursed by an insurance company? ...

By virtue of this administrative position, a partner could be considered the acquiror of the home for purposes of the HBTC and thus claim the HBTC if the member of the partnership is an individual, the home qualifies as a principal residence as defined in section 54 to the individual, and all of the conditions for the HBTC are otherwise satisfied as if the partner had personally acquired the home. …. ...

Moulds could be considered to be structures that are manufacturing or processing machinery or equipment within the meaning of paragraph (a) of Class 8 depending on the facts of each particular situation. ...

The distribution results in such non-resident beneficiary being considered to have disposed of all or a portion of the beneficiary’s capital interest in the Estate. ...

CRA stated: CRA…generally accepts that medical and hospital insurance plans offered by Blue Cross are considered PHSPs…. ...

The available credit would depend on whether amounts are considered to be paid or payable from the trust for Canadian tax purposes and whether the timing of the income inclusion by the beneficiary coincides with the payment of tax in the U.S. ...