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Respecting whether an addition to income under s. 110.5 is considered a permissive amount for purposes of IC 84-1, so that the Minister may allow this adjustment beyond the period provided in s. 152(4)(b)(iv), CRA agreed that this amount is permissive. ...

After noting a current GAAR review by Aggressive Tax Planning, the Directorate stated that LeCavalier " supports the application of GAAR… where the debt parking rules … were considered to have been misused or abused. ...

Accordingly…the Swap Contracts are considered to be inventory for the purposes of paragraph 85(1.1)(f). ...

After finding that the swaps qualified as "inventory" under the broad s. 248(1) definition and, therefore, as eligible property under s. 85(1.1)(f), the Directorate responded to the view of the TSO that "the election…was invalid," the Directorate stated: [T]he Taxpayer's derivatives could be considered as inventory for the purposes of subsection 85(1), which supports the Taxpayer's contention that XX intention was to record the transfer as inventory. ...

6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property-- summary under Excluded Property Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Excluded Property unpurchased goodwill is taken into account Is internally generated goodwill considered in determining whether shares of a foreign affiliate ("FA2") of a corporation resident in Canada qualify as "excluded property" of another foreign affiliate ("FA1") of the corporation? ...

…The payments by the Tenant for the utilities… would not be considered payments for the use of the Real Property but rather payments for the use of the services provided by the utility company…[and] would not be subject to withholding…. ...

Otherwise, if they are considered to be general damages for non-pecuniary damage, no portion of which could be designated as a specified portion of a qualifying amount. ...

" In indicating that the MRPS would be considered equity, CRA stated that "generally speaking, we will respect the form of the investment regardless of how it is accounted for or how it is treated for tax purposes in other jurisdictions," and that "payments of interest or dividends will derive their income tax consequences from the legal nature of the payment. ...

" In indicating that the MRPS would be considered equity, CRA stated that "generally speaking, we will respect the form of the investment regardless of how it is accounted for or how it is treated for tax purposes in other jurisdictions," and that "payments of interest or dividends will derive their income tax consequences from the legal nature of the payment. ...

" In indicating that the MRPS would be considered equity, CRA stated that "generally speaking, we will respect the form of the investment regardless of how it is accounted for or how it is treated for tax purposes in other jurisdictions," and that "payments of interest or dividends will derive their income tax consequences from the legal nature of the payment. ...