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However, CRA noted: [A]s compensation payments are not considered salary, wages, or other remuneration, they are not subject to the withholding of income tax, Canada Pension Plan contributions, and Employment Insurance premiums, irrespective of the recipient. ...

24 January 2001 External T.I. 2000-0028895 F- Contingent de versement/perte-- summary under Disbursement Quota Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(1)- Disbursement Quota investment of amount or depreciation in the investment is not the expending of an amount For the purposes of element A.1 of the definition of disbursement quota, when will an amount be considered expended where the foundation has received that amount and has invested it with an investment dealer, and the investment then fluctuates in value? ...

However, it should be noted that for the former common-law partner and the common-law partner to be considered a “spouse” or “former spouse” of the taxpayer, they must have been so, at a given time, after 1992, as required under the conditions of subsection 252(4). ...

CRA concluded: The day the TCEC of the associated corporation is considered to “arise” for the purposes of determining the conversion rate according to paragraph 261(5)(c) is the last day of the taxation year of the associated corporation for which it is computed because that is the day when the amount of the TCEC is determined pursuant to section 181.2 (hence when an amount relevant to computing the Taxpayer’s Canadian tax results is created). ...

…[T]he payment of the capital dividend account to certain shareholders would generally not be considered abusive for the purposes of subsection 245(2) if subsection 83(2.1) did not otherwise apply. ...

18 February 1994 External T.I. 9334285 F- Bare Trusts-- summary under Subsection 104(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(2) Where a settlor transfers property to a trust having the characteristics according with RC's understanding of a bare trust (the settlor is the sole beneficiary of income and capital during her lifetime, she retains the ability to revoke or amend the trust at any time and has the unfettered ability to deal with the property as she sees fit during her lifetime) but the settlor also stipulates that income and/or capital interest of other beneficiaries, which are contingent during her lifetime, will vest upon her death, the trust will be considered to be a bare trust until her death. ...

16 November 2000 External T.I. 1999-0009895 F- Revenu protégé- voiture de tourisme-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees reorganization expenses are eligible capital expenditures (now Class 14.1) Before confirming that no adjustment to safe income on hand was required in respect of eligible capital expenditures such as reorganization expenses, CCRA stated: Where reorganization expenses have been incurred in connection with a reorganization whose purpose is to preserve the entity, structure or commercial organization of the business, or whose purpose is to allow the continued existence, growth and development of the business, the Agency's position is that the expenses in question could be considered to be capital expenditures incurred for the purpose of earning income from the business and therefore eligible capital expenditures. ...

24 August 2000 External T.I. 2000-0011785 F- CRÉDIT D'IIMPOT FAVORISANT LE DÉVELOPEMENT-- summary under Paragraph 12(1)(x) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) Quebec tax credit not s. 12(1)(x) income until applied as an instalment or otherwise received CCRA indicated that the tax credit under the Quebec Taxation Act for promoting the development of information technologies would be considered to be included in the taxpayer's income under s. 12(1)(x) at the time the taxpayer became entitled to the credit (which required inter alia the submission of a copy of the certificate issued to the taxpayer by the Minister of Finance in respect of an eligible employee or qualified property) and it was applied as a payment of tax due by the corporation or at the time it was actually paid. ...

CCRA indicated that such policies could not be considered as part of a single group sickness or accident insurance plan because they were based in part on the corporation’s undistributed earnings, i.e., it was not based on the loss of employment earnings. ...

After noting that the corporation would be required to allocate the costs of the equipment between SR&ED and commercial activities, the Agency went on to indicate that labour, subcontracting, and materials expenses of a current nature relating to SR&ED activities that were "expenditures on or in respect of scientific research and exterior experimental development" as defined in s. 37(8)(a) to develop equipment that would be used 90% or more in the research laboratory and for equipment considered to be multi-purpose equipment, would qualify as current expenses for the purposes of s. 37 and for the calculation of the investment tax credit. ...