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Therefore, book debts that have been reduced by outstanding cheques on the date of the end of a fiscal period cannot be considered to have been paid on that date for the purposes of the tax under Part I.3 of the Act. ...

The CRA generally takes the position that supplementary pension benefits will be considered reasonable if: the terms of the plan are substantially the same as those of the RPP that applies to the same beneficiaries to whom the plan applies; and the benefits that can be paid under the plan are the same as the benefits that would have been paid under the RPP but for the defined benefit or money purchase limit. … [T]he basic contribution component of the Supplemental Plan appears to be largely consistent with the CRA’s general position outlined above. … However, the bonus contribution and vacation pay contribution components of the Supplemental Plan, as well as the Retirement Allowance Plan, appear to be primarily motivated by tax deferral considerations …[and] would most likely constitute an SDA. ...

. … [A] plan that otherwise meets all of the conditions in paragraph 3 of … IT-339R2 … is considered a PHSP as long as all of the expenses covered under the plan are medical or hospital expenses (“medical expenses”) or expenses incurred in connection with and within a reasonable time period following a medical expense, and all or substantially all (generally 90% or more) of the premiums paid under the plan relate to the coverage of medical expenses that are eligible for the medical expense tax credit (“METC”). ...

. … [F]or purposes of determining whether any particular location may be considered a RPE, we would generally consider an entire townhouse complex or apartment building to be one location. ...

However, it was not necessary to address this question “because PC1 also carries on a medical services business in Year 1 which would be considered a “related business” in respect of Spouse A.” ...

CRA stated: [T]he forgivable portion of the CEBA is an amount described in subparagraph 12(1)(x)(iv), because it is an amount received by the taxpayer from a person described in subparagraph 12(1)(x)(i), in the course of earning income from a business, and that amount “can reasonably be considered to have been received…as a…forgivable loan…in respect of...an outlay or expense”. ...

Assuming that the SEP meets the 12-hour requirement, the student in this case will likely be considered a PT qualifying student in respect of the study-abroad program. ...

Before finding that the taxpayer could not recognize a deductible expense as the rewards were earned, and that the applicable deductions were deferred until the points were redeemed, the Directorate stated: [T]he courts have held that an expense will not be considered to have been incurred unless the taxpayer has an obligation to pay money to someone [citing Burnco Industries, Northwood Pulp and General Motors]. … [and] that a legal obligation to pay under contract does not exist until all contractual preconditions to which the payment relates are fulfilled [citing Wawang Forest Products]. ...

CRA indicated that: “the creation of a Secondary Suite, either within or detached from a Homeowner’s principal residence, to be used for earning rental income will generally trigger a deemed disposition pertaining to the portion of the Property so converted pursuant to subparagraph 45(1)(c)(ii)”; the homeowner could make an election pursuant to s. 45(2) to defer the recognition of any resulting gain to a later taxation year; for purposes of the principal residence exemption, “if two housing units can be enjoyed and ordinarily inhabited separate from each other without access to the other (that is, if each unit is a self-contained unit with its own entrance, kitchen and bathroom) … they will be considered separate housing units” even if “the housing units are part of a single structure or are not on separate legal lots” – so that on disposing the homeowner would have to choose which of the two units to designate as principal residence for each applicable year, as discussed below; and although the ordinarily-inhabited condition under the principal residence definition would not generally be met for the Secondary Suite while it was rented to third parties, “[w]here a subsection 45(2) election is made by a taxpayer for a property that is the subject of a change in use, the property can qualify as the taxpayer’s principal residence for up to four taxation years during which the election remains in force, even if during those years the housing unit was not ordinarily inhabited by the taxpayer or one of the … family members ….” – so that the homeowner would be able to choose for such a year to designate the Secondary Suite rather than the balance of the property as that taxpayer’s principal residence. ...

Reg. 5907(1.4) will deny the amount prescribed to be FAT of Holdco under Reg. 5907(1.3)(b) to the extent it relates to the Compensatory Payment made to Loss LLC 2- on the basis that the Compensatory Payment cannot reasonably be considered to be in respect of a FAPL or a FACL. ...