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After noting that IT-244R3, para 2 stated that premiums on a life insurance policy held by an eligible donee, paid directly by an individual at the request of, or with the concurrence of, the donee, are considered to be a gift, CRA stated that the “premium for the ROPD rider will not be a gift where the beneficiary of the benefit payable on death under the ROPD rider is not an eligible donee.” ...

CRA stated: The payment of the insured sum is an obligation of the insurer and, subject to subsection 118.1(5.2), cannot be considered a gift from the policyholder since the proceeds of the life insurance policy never formed part of the patrimony of that person. ...

…[T]he series of transactions described in your letter appear to be for the purpose of obtaining tax benefits and could be considered abusive for the purposes of subsection 245(4). ...

4 March 2010 External T.I. 2009-0343851E5 F- Remboursement des cotisations à un club-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) reimbursements of employee fitness facility fees are considered principally for employees’ benefit if membership merely improves their performance through increased health Before concluding that it appeared likely that there was a taxable benefit from partial reimbursements to employees of fees for the use of recreational facilities for the purpose of engaging in physical activities, CRA stated: Generally, we do not consider the payment or reimbursement of club dues or membership fees to be principally for the benefit of the employer where the employee's participation in physical activities provides only an indirect benefit to the employer. ...

Respecting a requirement that there is no significant change in its membership or activities, this will not be considered to occur by virtue of a transfer of membership between parties not dealing at arm’s length or the issuance of additional memberships to them. ...

Also, the benefits acquired by means of the additional credits will be considered to have been provided through employee contributions. ...

Even if subsection 75(2) no longer applied, the attribution rules in sections 74.1 and 74.2 would have to be considered …. ...

Any dividend paid by the payer corporation is considered to be paid first out of the safe income on hand attributable to the recipient corporation's shares of the payer corporation. ...

However, … CRA … accepts that the portion of the dividend that may be considered safe income on hand attributable to the gain on the shares may be included in the GRIP of the corporation receiving the dividend if the corporation … designates such amount as a separate taxable dividend under paragraph 55(5)(f). ...

After noting its position in IT-145R that “the execution of orders from bulk stock is not considered a processing activity where the activities involved consist solely of counting or measuring and repackaging” and the position in Tenneco that “the goods must undergo a change in form, appearance or nature” in order for there to be processing, CRA stated: [A]lthough the taxpayer's processing activities have the effect of making … [the] products more marketable, we do not believe that there has been any change in the form, appearance or other characteristics of the products. ...