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24 September 2012 External T.I. 2012-0455741E5- AIM of the London Stock Exchange-- summary under Section 262 Summary Under Tax Topics- Income Tax Act- Section 262 AIM not designated The Alternative Investment Market ("AIM") of the London Stock Exchange ("LSE") is not a designated stock exchange,- but is considered a "recognized stock exchange" given that it is located in the UK (a member of the OECD which has a tax treaty with Canada), and it is a "stock exchange" in the general legal and commercial meaning of that term, i.e., "AIM is a market which allows for the organized purchase and sale of securities and it is considered to be a multilateral trading facility under UK law. ...

CRA stated that "the Treatment could be considered a medical service when it is offered to an individual for therapeutic or rehabilitative reasons," and that "a respiratory therapist is authorized to practise in the province of Alberta and would be considered a medical practitioner. ...

In providing general comments on whether the non-resident members of the partnership may be considered to carry on business in Canada, CRA stated: [I]n the case of a service business, the business would generally be considered to be carried on at the place where the services are performed. ...

20 January 2014 External T.I. 2013-0503871E5 F- Vente d'une érablière-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property maple syrup production quota is property if it is property under civil law Would a maple syrup production quota allocated to a maple sugar bush by an authority be considered property for tax purposes. After referencing s. 8.1 of the Interpretation Act, CRA stated: If it is determined that the maple syrup production quota is property under civil law, the maple syrup production quota will also be considered property for the purposes of the Act. ...

CRA stated: Where it can be established that [it]… is to be repaid from anticipated future Board awards, the loan or advance is not considered income to the employee and is not a deductible expense to the employer. …[I]t is the CRA's long-standing position that any interest accumulating on those advances/loans will not be considered a taxable benefit to the employee. ...

15 June 2012 External T.I. 2012-0434761E5 F- Dons liés à une police d'assurance-vie-- summary under Other Summary Under Tax Topics- General Concepts- Fair Market Value- Other 7 factors to be considered in valuing a donated life insurance policy CRA stated that, in valuing a life insurance policy donated to a charity, the principles set out in IC 89-3, paras. 40-41 should be applied, stating that: Factors to be considered in making this determination include: (a) the cash value of the policy; (b) the amount of policy loans available; (c) the face value; (d) the state of health of the insured and that person’s life expectancy; e) conversion privileges; (f) other policy terms, such as term riders and double indemnity provisions; (g) the replacement value. ...

CRA stated: [C]ompensation for damages received in respect of wages or other unpaid benefits (such as vacation) is generally considered taxable employment income under subsection 5(1). Similarly, in the case of retroactive reinstatement of an employee, compensation for taxable damages will be considered employment income and not a retiring allowance. ...

3 May 2010 External T.I. 2010-0358881E5 F- CIRD- construction d'un logement-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership individual is considered to be owner of home that is being constructed as soon as it is habitable Whether property used in renovation work on a home that was being constructed turned on whether the individual was the owner of this housing unit at the time of the renovation work. In this regard, CRA stated: In the situation where an individual constructs the individual’s housing unit on land owned by the individual, it is generally the CRA's view that the individual will be considered to own a housing unit for HRTC purposes as soon as the housing unit is habitable. ...

24 March 1994 External T.I. 9401245- SPECIFIED INVESTMENT BUSINESS-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business A taxpayer that rents storage facilities to clients who use the facilities to store raw materials used by them in their manufacturing activities likely would be considered to carry on a specified investment business given that the associated services of unloading the raw material when received from the clients, and loading them onto a transport truck or a train when the client requires the materials, would be considered to be ancillary to the main objective of renting storage facilities. ...

BUSINESS INCOME-- summary under Subsection 129(4.1) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4.1) Where a corporation whose principal business is farming owns certain rights to take petroleum from a well located on the farm land and leases such rights to an arm's length third party in consideration for a royalty, the royalty income will not be considered to be incidental to or to pertain to the corporation's farming business, nor will the rights be considered to be held or used principally for the purpose of gaining or producing income from the farming business. ...