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We wish to point out that the exclusion in paragraph 74.5(12)(a) demonstrates that Parliament considered RRSP income, which is included under paragraph 56(1)(h), to be income from property. ...

27 September 2004 External T.I. 2003-0048241E5- site reclamation costs-- summary under Paragraph 20(1)(m) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) no reserve if s. 9 inclusion Respecting whether the CRA would accept a reserve being deducted under s. 20(1)(m) in a situation similar to that considered in Deputy Minister of Revenue for Quebec v. ...

., before kindergarten for children in Quebec) should be considered to be child care expenses unless there is clear and conclusive evidence that the fees are educational expenses,” and also noted that “[f]ees charged for supervision during study sessions or other directed supervision activities could constitute child care fees if they are optional,” and that educational costs may include, for example, extracurricular activities and special schools. ...

The legal nature of the property is also an element to be considered when determining the number of housing units in the residence. ...

CCRA indicated that since the cost of the shares acquired by Holdco on exercise of the options was increased by the amount of the adjusted cost base of the options pursuant to s. 49(3)(b)(ii), only a portion of the safe income on hand that would otherwise be allocable (without the cost increase) to the acquired shares (as described in 1999-0011695) could reasonably be considered to be allocable to those shares since the effect of the cost increase was to reduce any unrealized capital gain on the acquired shares. ...

CCRA stated that “the mere fact that emigrant parents financially assist their adult children while they are completing their studies in Canada would not, in and of itself, prevent them from being considered non-residents of Canada, provided they sever all ties with Canada by leaving the country” and that “the residency status of a child over the age of majority residing in Canada will not be changed simply because the parents emigrate from Canada, even if the child is financially dependent on the emigrating parents while pursuing studies in Canada.” ...

28 June 2001 External T.I. 2001-0073205- SUBSTANTIAL ISSUER BID-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares Where a corporation proceeds with a substantial issuer bid at a price that is at a premium over the previous trading price of its shares on a stock exchange, the shares will not necessarily be considered to be purchased for a price in excess of their fair market value for purposes of the definitions of taxable preferred shares and short-term preferred shares. ...

30 July 2001 External T.I. 2001-0091465- Shares Exchange Arrangement-- summary under Paragraph 256(7)(e) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(7)- Paragraph 256(7)(e) Common shares of a CBCA corporation ("Canco") held by dissenting shareholders will no longer be considered to be outstanding shares of Canco. ...

9 October 2001 External T.I. 2000-0034915- REIMBURSEMENT OF STOCK OPTION BENEFIT-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) reimbursement by sub on stock option exercise Where a subsidiary reimburses its parent for the difference between the fair market value of shares of the parent company on the date of exercise of options on the shares of the parent previously granted to employees of the subsidiary, and the amount paid to the parent company by the employees who acquire the shares, there will be no inclusion in the income of the parent under ss.15(1), 12(1)(x) or 90 for the amount of the payment, provided that the payment is in respect of options granted after the arrangement was in place, or was in respect of the increase in the stock option benefit that, in the circumstances, may reasonably be considered to have arisen after the arrangement went into effect on options that were granted prior to the arrangement. ...

. … Consequently, the payment date is considered to be the date on which the cheque is honoured or discharged by the bank, which normally occurs … on the date on which the cheque in question is debited from the debtor's account. ...