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In finding that Opco’s safe income on hand at the safe income determination time (June 29) should be reduced by the s. 111(5.1) write-down, CCRA referred to the statement in the 1988 Robert Read paper that: If it is reasonable to expect that any of the income earned or realized in a stub period will be offset by losses in the remainder of the year, then the calculation of the safe income on hand for the stub period should reflect the anticipated losses, since that income could not reasonably be considered to be reflected in the inherent gain in the shares. ...

“[I]f an employee voluntarily adheres to the telework arrangement proposed by their employer, the employee is considered to have an obligation to use part of their home to perform the duties of employment and to pay certain expenses relating to this space devoted to working from home as long as the employee and the employer enter into a formal telework agreement.” ...

. … In our opinion, for the purposes of calculating the CEC of Amalco in Situations 1 and 2 described above, it should be considered that there is a continuation of the calculation of the CEC of Portfolioco and Subco in Amalco. ...

The DR amount of $74,500 for the 2000 TY would be considered to have been refunded to Bco, pursuant to subsection 160.1(4), as it was applied against Bco's Part I tax payable for the year. ...

For the purposes of the credit (OETC) under s. 122.3(1), are the periods of stay abroad considered to be interrupted by the leave periods: where it is expected that: (1) they will return within a short period of time (usually two weeks) to work abroad on the same contract or on a new contract entered into by Canco; (2) where, upon the return to Canada, there is no planned foreign assignment (although the employee in fact will return abroad after that so that the cumulative length of the stays abroad, including holiday periods in Canada, will exceed 6 months); or with the variation on Situations 1 and 2 (so as to constitute Situations 3 and 4) that Canco issues a termination notice to the casual employee at the end of each stay abroad? ...

Consequently, it seems to us that a payment made as “deferred salary” should not be considered a pension payment for the purposes of the Act and the Convention. ...

Accordingly, each of the three notional contribution components of the Supplemental Plan can be considered separately in determining whether the particular component is an SDA. ...

Where the jurisdictional law regarding partnerships provides that a partnership is an agreement among the partners to carry on business in common, each partner will be considered to be carrying on the business of the partnership. ...

CRA went on to gratuitously state: [A]ny additional payment that an IPP may be required to make in a particular year to comply with the IPP minimum amount rules in [Reg.] 8503(26) … is not considered to be a periodic pension payment. … Whether an IPP must make such a payment has to be determined each and every year by reference to the current value of the IPP’s assets and an age-based factor. … Similarly, a commutation payment made to a member or a beneficiary of a member in full or partial satisfaction of their entitlement to benefits under a defined benefit RPP is not a periodic pension payment. ...

After noting that the members were “employees” by virtue of holding offices, that the members' constituency offices could be their ordinary place of employment, and that s. “6(1)(b)(vii) … specifically excludes from income reasonable travel allowances, namely all amounts received by an employee from the employer for travelling away from the municipality (and the metropolitan area, if there was one) where the employer’s establishment, at which the employee ordinarily worked, was located,” CRA stated: An allowance for accommodation expenses will not be considered reasonable … if it does not represent an estimate of the cost of accommodation that may be incurred by the employee during the travel that generated entitlement to the allowance. ...