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[F]ollowing the taxpayer's US expatriation and during this subsequent 10-year period, the full amount of US withholding tax on the future taxable distributions from the US pension will be considered non-business-income tax paid by the taxpayer to a government other than Canada for purposes of a foreign tax credit claim pursuant to subsection 126(1)…. ...

23 December 2014 External T.I. 2014-0551841E5- Subsections 44(1) and 69(11) of the Act-- summary under Subsection 44(1) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(1) implied receipt of deemed s. 69(11) proceeds Would proceeds of disposition deemed to arise by s. 69(11) be considered an amount that has become receivable by the taxpayer as proceeds of disposition for purposes of the replacement property rules in s. 44(1)? ...

The Tax Court [HSC Research, 95 DTC 225] stated that a corporation without share capital should be considered to be controlled by the person appointing the majority of the board of directors. … Accordingly…we assume that Municipality would be the person who could elect the majority of the Board…. ...

However, where the rental unit is occupied by the taxpayer or members of his or her household during the period for which the rent is paid, it is the CRA's view that the rental payments would not be considered "costs of cancelling a lease"…. ...

In finding that the employee’s income was not exempt, CRA noted that “the fact that the work is for the benefit of Indians living on reserves appears to be the only factor connecting the employment income to a reserve,” and indicated that in Monias this was considered to be an insufficient connecting factor. ...

16 February 2016 External T.I. 2015-0618601E5- Earned or Unearned Revenue-- summary under Paragraph 20(1)(m) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) no deferral for amount included under s. 56.4(2) or 12(1)(x) CRA considered that a lump sum payment received from a major supplier for signing a 15-year “supplier loyalty agreement” would be includible in income when received under s. 56.4(2) on the grounds that the loyalty covenant was intended to restrict the way in which the taxpayer made its purchases (i.e., it was in respect of a “restrictive covenant”) – or, failing that, it would be included in the taxpayer’s income as an inducement under s. 12(1)(x). ...

CRA considered that the debt forgiveness rules could thereby apply to the debt because the deemed settlement under s. 80.01(8) occurs at the time of the acquisition, whereas the s. 53(1)(f.1) bump to the acquirer’s ACB occurs only immediately after that time ...

11 August 2015 External T.I. 2014-0527291E5 F- Remboursement de frais médicaux-CIMAD-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) correction in CRA position not applied on a retroactive basis After finding that the reversal by 2013-0490901I7 of 2001-0113237 (respecting the Ontario Healthy Homes Renovation Tax Credit) also applied to the Quebec Tax Credit for Home-Support Services for Seniors ("CIMAD"), so that the CIMAD also was not considered to reduce the amount of eligible medical expenses for the Medical Expenses Tax Credit, CRA stated: When a change of position is issued in a technical interpretation, and that change is for the benefit of the taxpayer, it usually applies to present and future assessments and reassessments. ...

CRA responded (TI translation): [A] limited partner of an LP will be considered to be carrying on the business of the LP in applying subsections 39(4) and 39(5). ...

CRA considered that neither of these two deemed subtrusts is required to report foreign property on T1135s provided that all the foreign property is held in the non-resident portion trust rather than the particular trust, stating: A specified Canadian entity is defined by subsection 233.3(1) as a taxpayer resident in Canada with certain exceptions which are not applicable... ...