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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..... ...

Consequently, transactions other than those specifically mentioned in the definition can be considered as dispositions. ...

CRA stated: [U]nder paragraph 5907(11.2)(a) … if an FA is resident in a country with which Canada has a treaty but for the purposes of that treaty the FA is not considered to be resident of that country, it will be deemed not to be a resident of the designated treaty country for the purposes of section 5907 …. … As stated in paragraph 15 of Interpretation Bulletin IT-391R, a company is generally resident in the country in which its central management and control is exercised. ...

. … [W]here a franchisor and a franchisee are at arm's length … the shares of the franchisor held by a franchisee could be considered to be used in the business operated by the franchisee, to the extent that the subscription is a condition of membership under the banner, and the shares are pledged as security to the franchisor to secure the obligations of the franchisee. ...

If the deduction in a taxation year exceeds the amount of employment income for the year, then there will be an employment loss, which will be considered a non-capital loss as defined in subsection 111(8). ...

CRA responded: In most treaties where management fees or charges are not specifically dealt with, the business profits provisions are considered to include reasonable management fees. ...

Accordingly … only the taxable capital of the CCPC (Xco) should be considered for purposes of the proposed amendments to subsection 125(5.1) since the facts submitted indicate that the associated corporation (Yco) does not carry on business through a permanent establishment in Canada within the meaning of subsection 400(2) of the ITR. ...

We consider that the impact on accumulated earnings of other non-arm's length transactions must be considered in light of the facts of each particular situation. ...

It is our view that amounts of $15 to $20 per day paid to volunteers to defray the cost of using a car or meals during volunteer activities, even to travel from home to work, would not be considered employment income if they are the only amounts received by them. … In addition, where a worker uses an automobile owned by the organization, not only for volunteer activities, but also for commuting to and from work, we are also of the view that this benefit does not give rise to tax consequences, provided that the cost of the automobile is reasonable and that it is the only personal use made of it. ...

(s. 871(m)) characterization, as a dividend, of a principal or derivative payment by a Canadian issuer to a Canadian investor, is irrelevant to T5 reporting What are the Canadian tax reporting requirements respecting a payment made under a Canadian financial contract (i.e. a contract between an entity resident in Canada and a Canadian-resident investor) that is considered “dividend equivalent amount” under new Code s. 871(m)? ...