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CRA responded: [C]ompensation received by a former employee from the employee’s former employer for damages as a result of wrongful dismissal will be considered as a retiring allowance and will be required to be included in computing the former employee's income under subparagraph 56(1)(a)(ii). ... Consequently, compensation received for renouncing rights of reinstatement received in settlement of union grievances will generally be considered to be a retiring allowance and will be required to be included in the computation of the former employee's income by virtue of subparagraph 56(1)(a)(ii). ...

After noting that “An immovable is normally considered to be a single property unless it is legally subdivided into two or more separate properties,” so that in this situation the partial change-in-use rule in s. 45(1)(c) would be considered to apply, CRA stated: As indicated in paragraph 30 of Interpretation Bulletin IT-120R6, Principal Residence, a taxpayer cannot make an election under subsection 45(3) where the change in use of a property is a partial change in use. ...

CRA stated: An immovable is normally considered to be a single property unless it is legally subdivided into two or more separate properties. ... Consequently, subparagraph 45(1)(c)(i) would apply so that, in this situation, the partial change-in-use rule in s. 45(1)(c) would be considered to apply. ...

26 July 2010 External T.I. 2010-0364721E5 F- Revenus de bien et d'entreprise-- summary under Subsection 1100(14) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(14) rental property restriction rule applies to business properties as well/"principally" references over 50% of the time After concluding that “the operator of a bed and breakfast, who has a personal residence in which bed and breakfast rooms are rented out on a short-term basis, is generally considered to be carrying on a business” rather than having a source of property income, CRA stated: Whether or not the rental of a building by an individual is a business, the property may be considered a "rental property" for purposes of the CCA restrictions under subsection 1100(11) …. ...

Generally, those whose business involves trading in the underlying instruments and those who trade futures contracts are not considered to be speculators and report their transactions on income account. In our view, a mutual fund trust or corporation would not be considered to be a “speculator” within the meaning ascribed to that term in the Bulletin. ...

9 February 2017 External T.I. 2016-0657531E5- Deemed resident trust and "designated beneficiary"-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 210- Designated Beneficiary- Paragraph (a) s.94(3) trust can cause a trust of which it is beneficiary to be subject to Part XII.2 tax Is a non-resident trust, which is deemed to be resident for various purposes under s. 94(3)(a), considered to be a “non-resident person” for purposes of para. ... Accordingly, such a non-resident trust is still considered to be a non-resident for purposes of the definition of “designated beneficiary” in subsection 210(1), and is therefore a “non-resident person” for purposes of this definition. ...

31 March 2017 External T.I. 2016-0675221E5- T4A-- summary under Subsection 200(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(1) No T4A for rent Is an amount paid to an individual as rent for the use of a facility is considered an amount paid as a fee, commission or other amount for services and thus required to be reported on a T4A slip? ... CRA responded: [A]n amount paid as rent for the use of a property would normally not be considered a fee, commission or other amount for services described in paragraph 153(1)(g) of the Act. ...

CRA responded: [T]he payment of a lump sum to cover the balance of unused sick leave accumulated over the years can be considered a retirement allowance. However, when the payment of the balance of such leave is made annually in accordance with an employment agreement … this payment is not in recognition of long service when the payment is made upon the employee's departure … [and] is usually considered employment income ...

16 June 2017 External T.I. 2016-0674541E5- Mineral Certification-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) exploring a placer jade deposit did not qualify as CEE The Minister of Natural Resources advised CRA that nephrite (a type of jade) to be extracted from the in-situ deposits on the subject property was an industrial mineral contained in non-bedded deposits – but excluding placer nephrite deposits, which were considered to not qualify as “a mineral deposit in respect of which...the principal mineral extracted is an industrial mineral contained in a non-bedded deposit.” CRA itself considered that the placer nephrite deposits did not qualify as a “base or precious metal deposit.” ...

CRA stated: In general, a lump sum payment for the balance of unused sick leave accumulated over the years may be considered a retiring allowance if the payment is made on or after the employee retires from an office or employment. ... In such a case, the amount is usually considered employment income. ...