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CRA responded: Such renunciations could not be considered disclaimers for the purposes of the Act because they would be transfers of property from some of the intestate heirs (Children A) to Mrs. ...

CRA responded: Such renunciations could not be considered disclaimers for the purposes of the Act because they would be transfers of property from some of the intestate heirs (Children A) to Mrs. ...

In indicating that the shares of the two Holdcos qualified as shares of family farm corporations under the “Definition”, CRA stated: [A] corporation that is a member of a partnership would be considered to be carrying on the same business as that carried on by the partnership. ...

The central management and control of a corporation is usually considered to be exercised by the members of the board of directors. ...

Where, in the context of a transfer of property, the general rules of contract and obligation and all the specific conditions of a gift in civil law are satisfied, we are of the view that the gift will generally be considered a gift for the purposes of the Act. ...

CRA indicated that it considered the following statement in IT-352R2, para. 1 was consistent with Longtin: “Subject to certification by the employer … subparagraphs 8(1)(i)(ii) and (iii) allow a taxpayer, in computing income for a taxation year from an office or employment, to deduct amounts paid in the year as expenses for office rent, supplies and salary to an assistant or substitute. ...

Income Tax Technical News No. 29 … [states]: [A] tax credit or a reduction in the tax calculation is considered to be received at the earliest of: when the amount is applied as a reduction of instalment payments to be paid by the taxpayer, if it is credited to his instalment account by the fiscal authorities; or when all the conditions for its receipt are met, at the earliest of: when it reduces the tax payable for a taxation year, or when it is paid, if it allows for or increases a tax refund. ...

Income Tax Technical News No. 29 … [states]: [A] tax credit or a reduction in the tax calculation is considered to be received at the earliest of: when the amount is applied as a reduction of instalment payments to be paid by the taxpayer, if it is credited to his instalment account by the fiscal authorities; or when all the conditions for its receipt are met, at the earliest of: when it reduces the tax payable for a taxation year, or when it is paid, if it allows for or increases a tax refund. ...

Where construction employees received a daily allowance to cover the costs of meals and accommodation while away from home and at a construction site, it was agreed that the following portions thereof would be considered to be for meal expenses that were subject to the s. 67.1(1) limitation (to the extent that the s. 67.1(2) exceptions did not apply): Amount of daily allowance Meal portion $75 and under 15% of the balance Between $75 and $100 $11.25 plus 20% of the balance Between $100 and $125 $16.25 plus 30% of the balance Over $125 $23.75 plus 40% of the balance CRA went on to state: [T]he agreement with the CCA can be applied to all taxpayers in circumstances similar to those described in the agreement, regardless of the industry in which they are engaged. ...

CRA stated: As indicated in … IT-213R, the amount or value of a prize received by a taxpayer from a lottery scheme is not taxable as either a capital gain or income unless … the prize can be considered, inter alia, to be income from employment. … [A]lthough the item was won by chance by an employee, it was received by the employee in the course of the employee’s employment since only employees could participate in the draw. ...