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2 February 1994 Internal T.I. 9400597- DEFINITION OF SPOUSE-- summary under Subsection 252(4) Summary Under Tax Topics- Income Tax Act- Section 252- Subsection 252(4) Once a common-law relationship has been severed (by not cohabiting for at least 90 days because of a breakdown in the relationship) the common-law marriage will be considered to have been re-established the moment cohabitation has resumed, i.e., there is no need for the couple to satisfy another 12-month test period. Once a separation has occurred, they were considered to be common-law spouses until the expiration of the 90-day period. ...

10 February 1994 Internal T.I. 9402247- DEFINITION OF SPOUSE-- summary under Subsection 252(4) Summary Under Tax Topics- Income Tax Act- Section 252- Subsection 252(4) Where a couple who had been living together continuously for under 12 months have a child, their date of marital status will not be considered to have changed until the date of birth. Similarly, where they commenced living together, they were not considered to be common-law spouses until 12 months later. ...

23 January 2004 Internal T.I. 2003-0051931I7- Damages Paid to RPP and RRSP-- summary under Paragraph 146.3(2)(f) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(2)- Paragraph 146.3(2)(f) Damages in respect of breach of contract or a tort paid by an employer to compensate for investment losses caused by the employer as administrator of a registered plan which has been established for a group of employees are not considered employment income to the employees; nor is the employer or the employee considered to have made a contribution to the plan as a consequence of the payment of the damages. ...

23 January 2004 Internal T.I. 2003-0051931I7- Damages Paid to RPP and RRSP-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) Damages in respect of breach of contract or a tort paid by an employer to compensate for investment losses caused by the employer as administrator of a registered plan which has been established for a group of employees are not considered employment income to the employees; nor is the employer or the employee considered to have made a contribution to the plan as a consequence of the payment of the damages. ...

CRA further indicated that the terms "ordinarily reside" (in s. 62) and "ordinarily resident" (in s. 250(3)) have the same meaning and that “the notion of ‘ordinarily reside’ relates more to everyday life than to the permanent nature of the situation, CRA then went on to indicate that the question of whether the reimbursement of expenses of selling a residence at Location 1 in Canada, which had continued to be held by an employee after his relocation to a job abroad at Location 2, could be treated as a taxable benefit if such residence was sold at the time the employee was relocated again to another location and position abroad at Location 3, turned on whether he should be considered to ordinarily reside at Location 2, stating: If it is established, on the facts, that the employee ordinarily resided at each of Location 1, Location 2 and Location 3, moving from Location 1 to Location 2, and then from Location 2 to Location 3, could each be considered as an "eligible relocation" if all other conditions are met. Expenses related to the sale of the residence at Location 1 at the time of the move from Location 2 to Location 3 would not be deductible in computing the taxpayer's income because the residence at Location 1 would no longer be considered to be the old residence during the eligible relocation from Location 2 to Location 3. … ...

What date should be considered in determining whether the expenses incurred are CEE or Canadian development expense ("CDE")? After first noting that as the expenses were incurred after June 20, 2013, they did not qualify as CEE in paragraph (g) of the definition, CRA stated: [I]f the written agreement described in paragraph (g.3) of the definition of CEE in subsection 66.1(6) is the written agreement (dated December 31, 2012) for the issuance of a flow-through share, the $2 million expense could be considered CEE by virtue of paragraph (g.3) of the definition of CEE in subsection 66.1(6) because the expenses are incurred before 2017. ... Thus, since the expenses in the amount of $2 million were incurred by Corporation X after June 20, 2013 but before 2015 and are eligible pre-production mine development expenses, the expenses paid by Corporation X to the subcontractor are considered to be CEE. ...

(b)(i)(A) of A of “qualifying rent expense,” the Directorate stated: [T]he entire time period that the particular qualifying property has been owned must be considered. ... It also indicated: Generally, a debt obligation is considered to arise whenever a binding liability is created and the principal amount of the liability can be quantified. … Whether a particular debt obligation, such as a line of credit, a demand loan or a forgivable loan, is secured by a mortgage or hypothec on the qualifying property is a question of fact and law …. [A]lthough interest paid on a debt obligation (such as a line of credit, a demand loan or a forgivable loan) secured by a mortgage or hypothec on a qualifying property may be considered qualifying rent expense, if it has no amortization period, the principal amount of the debt obligation would not be included in the LTPA Limit described in clause (b)(i)(A) …. ...

23 April 1992 Memorandum 921211 (September 1992 Access Letter, p. 39)-- summary under Dividend Rental Agreement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Dividend Rental Agreement A situation in which a securities dealer would borrow a share on which either a cash dividend, or a stock dividend valued at a 5% discount from the market price, was payable, elect to receive the stock dividend, sell the stock dividend upon receipt and pay a dividend compensation amount and a portion of the profit on the transaction to the lender of the share, would be considered a securities lending arrangement, and might also be considered a dividend rental arrangement. ...

23 April 1992 Memorandum 921211 (September 1992 Access Letter, p. 39)-- summary under Securities Lending Arrangement Summary Under Tax Topics- Income Tax Act- Section 260- Subsection 260(1)- Securities Lending Arrangement A situation in which a securities dealer would borrow a share on which either a cash dividend, or a stock dividend valued at a 5% discount from the market price, was payable, elect to receive the stock dividend, sell the stock dividend upon receipt and pay a dividend compensation amount and a portion of the profit on the transaction to the lender of the share, would be considered a securities lending arrangement, and might also be considered a dividend rental arrangement. ...

…[W]here a person acquires a business as a going concern from a person who, immediately before that time was a financial institution, the person acquiring the business is considered to be a financial institution for the remainder of the taxation year if the acquired business is continued as the purchaser's principal business immediately after the purchase. However, the person acquiring the business would be considered to be a listed financial institution only if it is a person referred to paragraph 149(1)(a). ...