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In finding that the allowance likely was not taxable under s. 6(1)(b), CRA stated: [T]he trips made by the representative with his motor vehicle to go from the employee’s residence to the first client place of business and from the last client place of business to the individual’s residence could be considered to be trips made in the performance of the duties of his office or employment, as long as such client places of business do not constitute a regular place of work to the individual. … [I]t is unlikely that the clients' places of business would constitute a regular place of work of the representative. ...

After referring to s. 37(13), CRA stated: [A]dministrative support tasks in respect of the activities of a subsidiary of a taxpayer would not be considered to be SR&ED of the taxpayer because the condition in paragraph 37(13)(b) is not satisfied since the administrative support tasks would not be SR&ED of the subsidiary …. ...

CRA indicated that “there is nothing in the wording of subsections 44(5) and 13(4.1) that would lead to the conclusion that the acquisition of a replacement property from a related person or from a corporation in which the taxpayer holds shares is prohibited for the purposes of these provisions” – although it indicated that whether s. 69 or 15 applied would need to be considered. ...

If preferred shares of the corporation are issued to the individual as a stock dividend on the common shares, would those preferred shares qualify for the transitional relief on the basis of being considered to have been held on and after April 26, 1995, given that s. 248(5)(b) deems a share received as a stock dividend on another share of the capital stock of a corporation to be property substituted for that other share? ...

8 November 2004 External T.I. 2004-0067161E5 F- Change étranger-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) examples of FX conversions into and out of USD account of US share investor An investments corporation, which has a bank account in the U.S. that is used in its 2003 year to fund the purchase of shares of U.S. corporations, deposit the proceeds from their sale and dividend income thereon and interest income on the account balance was considered by CRA to have the consequences under s. 39(2) described in the 4 th column below of the transactions involving that USD account referred to in the 3 rd column. ...

Such foreign tax paid does not qualify for the foreign business income tax credit under s. 126(2) since such business income is not considered to be income from a business carried on outside Canada, and instead entitles the CCPC to the s. 126(1) credit. ...

Such foreign tax paid does not qualify for the foreign business income tax credit under s. 126(2) since such business income is not considered to be income from a business carried on outside Canada, and instead entitles the CCPC to the s. 126(1) credit. ...

A and B staying with them on weekends, CRA then considered whether s. 18(12) be avoided if Mr. ...

CRA responded: [Under] the principle in … Poulin … an expense paid in a year in which a taxpayer is no longer carrying on business may be deducted in that year since the taxpayer cannot be considered to have ceased to carry on business as long as the taxpayer is engaged in following up on actions taken by the taxpayer in the course of carrying on business. … [P]remiums paid by a taxpayer to maintain liability insurance in respect of actions taken in the course of carrying on the taxpayer's business would be deductible in computing the taxpayer's income. ...

Regarding a submission based on 729658 Alberta that only $300,000 of the deemed dividend would be deemed to be a capital gain, CRA indicated that this situation was different from that considered in 729658 Alberta, and stated: [T]he safe income on hand attributable to the 100 common shares of Opco held by Holdco (after the transfer by Mr. ...