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. … [A] partnership would generally be considered a "taxpayer" for the purposes of subsections 51(1), 85.1(1) and 86(1) and would therefore be entitled to rely on the rules contained therein …. ...

. … [A] partnership would generally be considered a "taxpayer" for the purposes of subsections 51(1), 85.1(1) and 86(1) and would therefore be entitled to rely on the rules contained therein …. ...

However, where an individual receives a lump sum payment in lieu of future benefits that would have been otherwise paid under an employer long-term disability plan, in circumstances such that the payment can reasonably be considered to be proceeds of disposition of an interest in an insurance policy, it is our view that the proceeds are not taxable under paragraph 6(1)(f) of the Act or as a capital gain pursuant to subparagraph 39(1)(a)(iii) …. ...

31 January 2006 External T.I. 2005-0151041E5 F- Régimes de sécurité sociale étrangers-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 plan recognized as a pension plan under Art. 29(5) of the Cda-France Convention cannot be an EBP In response to a query as to whether contributions made by an employer to certain French social security plans are considered taxable benefits to employees who are residents of Canada for a period not exceeding 5 years and an expressed view that such plans are employee benefit plans ("EBP") so that no amount is to be included in the employee's income as a benefit under s. 6(1)(a)(ii), CRA stated: [W]here a pension plan is recognized for the purposes of paragraph 5 of Article 29 of the [Canada-France] Convention, it is our view that it is not an EBP. ...

27 January 2006 External T.I. 2005-0164611E5 F- Société immobilière de pension- sens de location-- summary under Clause 149(1)(o.2)(ii)(A) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(A) providing meals, medical services and housekeeping in a seniors apartment would put the corp. offside Regarding whether a pension fund real estate corporation that owns (in joint tenancy with a taxable corporation) a building that includes apartments rented to independent seniors can be considered to have limited its activities to the leasing or managing of capital property that is real property for the purposes of clause 149(1)(o.2)(ii)(A) if it provides meals, medical services and housekeeping that are billed separately, CRA stated: [T]he services provided by the Corporation … do not constitute leasing or managing capital property for the purposes of clause 149(1)(o.2)(ii)(A). ...

. … [I]n other types of situations where property is used for commercial and residential activities and/or where the particular property is not zoned as being residential, no portion of a mortgage debt on such a property would be considered as being a debt secured by way of mortgage on a house or a housing project for the purpose of subsection 130.1(6) …. ...

21 August 2018 External T.I. 2018-0771811E5- 120.4 Excluded Shares-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares- Paragraph (b) 10% of votes and FMV tests can be satisfied on a collective basis Where a shareholder has non-voting common shares with a fair market value (“FMV”) equal to 20% of the total FMV of the corporation and “skinny” voting preferred shares having a nominal FMV but having 20% of the total votes of the corporation, would the shares be considered excluded shares assuming the tests in paragraphs (a) and (c) of the definition are met? ...

We have reconsidered our previous position with respect to the payment of such fees by the annuitant outside of the RRSP or RRIF trust and we are now of the view that the payment of such fees by the annuitant would not be considered a premium or gift contributed to the RRSP or RRIF. ...

3 January 1997 External T.I. 9639365- REIMBURSEMENT OF RRSP ADMINISTRATION FEES-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium contribution to plan to fund admin fees is a premium The Department briefly stated: [W]here the annuitant makes a payment to his or her RRSP trust as a contribution under the trust to be applied for the purpose of providing the annuitant with a "retirement income" (as defined in subsection 146(1) of the Act) on maturity, the payment is considered a payment of a "premium" as defined in subsection 146(1) … unless it is a payment excluded in the conclusion to that definition. … [A]dministration or trustee fees can also be paid directly by the annuitant outside the trust and that there is no deduction for such payments made after March 5, 1996. ...

16 June 1997 External T.I. 9711005- SAFE INCOME/PART IV TAX-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Any dividend paid by a payer corporation is considered to be paid first out of the safe income on hand attributable to the recipient corporation's shares of the payer corporation. ...