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In finding that such commuted value was to be included at the time of the transfer in the individual’s income pursuant to s. 56(1)(a)(i), CRA stated that “the Individual is considered to have constructively received the benefit on the basis that, by virtue of the Transfer, the benefit has been set apart for the Individual”- and further found that even if the constructive receipt doctrine were found not to apply, s. 56(2) would apply to include the commuted value in the individual’s income on the basis that the individual had directed or concurred in the payment of an amount to a third party (the UK SIPP) and that amount, had it been paid to the individual, would have been included under s. 56(1)(a)(i). ...

Would either CCPC be considered to have earned income described in s. ...

Regarding the exception in (e)(i), it stated: [A] minivan that originally had more than three seats could still be considered to have a maximum of three seats … for the purposes of subparagraph (e)(i) of the definition of "automobile" in subsection 248(1) if the modification reducing the number of seats to a maximum of three seats is of a permanent nature. ...

CRA indicated that where in a particular year, more than 50% of a particular property is being used for some purpose other than farming (or fishing) or is otherwise vacant or idle, generally speaking, such non-farming use would result in the entire property not being considered as being used principally in the business of farming in Canada for the year. ...

27 February 2024 External T.I. 2024-1006681E5- Arrangements subject to trust reporting-- summary under Subsection 150(1.3) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.3) an agent not acting in relation to a trust has no trust reporting obligations Would the trust-reporting rules apply to an arrangement under which a person can reasonably be considered to act as agent for one or more other persons with respect to all dealings with certain property, without the arrangement being a trust or giving rise to the creation of a trust under the applicable private law, and without any valid trust (under the applicable private law) being otherwise involved in the arrangement? ...

…[I]f it can be shown that there is a sufficiently clear connection between the death of the deceased parent and the disposition of the housing unit by the child beneficiary, then it may be possible to conclude that the disposition of the housing unit by the child beneficiary can reasonably be considered to have occurred due to the deceased parent’s death, and the gain realized on the disposition would not be deemed to be business income by virtue of the application of subsection 12(12) …. ...

. … Where it can be established that a taxpayer has disposed of a housing unit located in Canada, which was owned for less than 365 consecutive days, due to or in anticipation of the inability or lack of means to pay their debts as they become due, then the housing unit will not be considered a flipped property. ...

After noting that property located outside Canada can potentially qualify as a taxpayer’s principal residence, and that “[e]ven if a person inhabits a housing unit only for a short period of time in the year, this may be sufficient for the housing unit to be considered ordinarily inhabited in the year by that person,” CRA stated: Notwithstanding that travel guidance and travel restrictions of varying degrees were in effect during the COVID-19 pandemic, for a property to qualify as a taxpayer’s principal residence as defined in section 54 of the Act for the year, the condition that the property be ordinarily inhabited by the individual, the individual’s spouse, common-law partner, former spouse, former common-law partner or child in the year is still required to be met. ...

[U]nder subsection 118.1(2.1) of the Act, gifts will be considered to have been claimed in determining an individual's charitable donations tax credits in the order in which they were made (i.e., on a “first-in, first-out” basis). ...

In finding that Sub-jurisdiction A would not be considered a “designated treaty country” under Reg. 5907(11), CRA first noted that such provision clearly provides that a designated treaty country does not include any territory to which the relevant tax treaty or TIEA does not apply, and then stated: [S]uch [subsequent] agreement will not, by itself, extend the territorial scope of the Canada- Country A tax treaty to Sub-jurisdiction A. ...