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The Directorate went on to state, respecting where the administration of the estate has been completed prior to the DPBNR being in a position to pay the amount: [T]he CRA will not object to the beneficiaries of the estate who are entitled … to all or part of the survivor benefit amounts being considered to have received those amounts directly from the DPBNR. ... If so, it is pursuant to subparagraph 56(1)(a)(i) that the amounts received or considered received by the beneficiary(ies) of the estate are to be included in computing the beneficiary(ies)’ income. ...

It is arguable that the acquisition of the Class B MRPS is not considered part of the ordinary course of business carried on by XXXXXXXXXX, but rather the acquisition may be considered an isolated and special transaction that is not part of a course of conduct that involves repeated dealings of a similar nature. ...

"While a truck rental company would not be seen as having converted capital property to inventory when the leased trucks are being replaced only when worn out or obsolete... where leased vehicles are withdrawn from leasing part prior to that time and are sold as an integral part of the taxpayer's normal business operations, a conversion of the trucks to inventory is considered to occur prior to their sale. ...

"While a truck rental company would not be seen as having converted capital property to inventory when the leased trucks are being replaced only when worn out or obsolete... where leased vehicles are withdrawn from leasing part prior to that time and are sold as an integral part of the taxpayer's normal business operations, a conversion of the trucks to inventory is considered to occur prior to their sale. ...

14 December 2011 Internal T.I. 2011-0424221I7- copyright music-- summary under Subsection 212(5) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(5) copyrighted music incorporated into film A licence with a US-resident copyright holder of a musical work enabling the taxpayer to "fix, record, dub and edit the music in synchronized or timed relation to visual and audio elements" for a fixed fee with caps on usage (i.e. a maximum number of video promotions broadcast) is considered to be a royalty for a musical work under s. 212(1)(d)(vi) and is not a payment for a right to use a motion picture film or video product under s. 212(5), notwithstanding that the music is used in "promos" (i.e., promotions of program viewership) aired on Canadian telecasts: Canco is not paying an amount to US for "a right in or to the use of a motion picture film or video product"; instead, Canco is paying US for the right to use/reproduce copyrighted music which will be incorporated into film or video produced in Canada. ...

The Directorate stated: [A]ssuming the royalties are not deductible by the BD partnership in computing its income from a source in Canada, by virute of paragraph 212(13.1)(a), the BD Partnershp will not be considered to be a person resident in Canada for purpoes of Part XIII.... ...

11 June 2014 Internal T.I. 2014-0521411I7- 149(1)(c)-- summary under Paragraph 149(1)(c) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(c) adoption of Tawich In the course of a general discussion and before indicating that certain agencies and boards likely did not qualify, CRA stated: The CRA's previous position was that an entity could be considered a municipality for the purpose of paragraph 149(1)(c) of the Act on the basis of the functions it exercises. ...

In finding that s. 80 did not apply in respect of the forgiveness of amounts owing by Canco under the Guarantees, the Directorate noted (respecting s. 20(1)(c)(i)) that "Canco should not be considered to have borrowed money under the Borrowing" and (respecting s. 20(1)(c)(ii)) "the amounts owing by Canco were not amounts payable for property acquired for the purpose of gaining or producing income from property. ...

Thus, the witness will be considered to be carrying on a business…. [However] a witness is placed under the protection of the SQ where there are legitimate concerns as to his and his family's security. ...

" Accordingly: the Loan represents indebtedness owed to the (Canadian resident) by a non-resident person(s) and therefore constitutes "specified foreign property"…because… for the purposes of paragraph (g) of that definition, each of the partners would be considered to owe the full amount of the indebtedness incurred by the Partnership. ...