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In commenting on the “actively engaged on a regular and continuous basis” test, CRA stated:]T]his requirement will be considered satisfied if the individual "is actively engaged" in the day-to-day administration or activities of the farming business. ...

Respecting a proposal that such recapture be prorated between active business income and property income based on the respective periods of time that the property generated the two types of income, the Directorate stated: [T]he CRA's position is that any recapture of capital cost allowance on the disposition of the building would also be considered to be active business income. ...

Respecting options with FMV exercise prices granted by the corporate employer which expire on a pro-rata basis over a five-year period, and which are exercisable upon the corporation subsequently notifying of its decision on the number of options that each employee may exercise, the Directorate stated: [A]n agreement to issue shares… would be considered to arise only at the time the notice is sent by the corporation to the employee and only in respect of the number of shares set out in the notice. ...

CRA considered a trust established by a CCPC to acquire and hold shares of the corporation for employees, with allocations among the employees and distributions entirely at the discretion of the trustees. ...

The Directorate then noted that the interest in the LP held by the Crown agent and the debt owing to the Crown agent were property of the Quebec government, and stated: Therefore, it is the Government that must be considered for the purposes of subparagraph 181.2(3)(g)(i). ...

3 March 2011 Internal T.I. 2010-0387281I7 F- Déduction- personnel des Forces canadiennes-- summary under Paragraph 110(1)(f) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(f) member of the Canadian Forces is an officer or non-commissioned member who is a member of the Regular or Reserve Force In response to a query as to whether the taxpayer is considered a member of the Canadian Forces and if the missions in which the taxpayer has participated qualify as either international operational missions or prescribed missions, CRA responded: Under the Act, it is the responsibility of the Department of National Defence to identify international operational missions that have a risk premium of level 3 or higher. ...

The amount of the Canadian exploration expense otherwise considered to be incurred by the Purchaser was to be reduced by the value of the warrants. ...

After indicating that the amount of the Canadian exploration expense otherwise considered to be incurred by the Purchaser was to be reduced by the value of the warrants, the Directorate commented on their valuation as follows: In determining the portion of the total consideration for the warrants, we would consider the amount that would have been the benefit under subsection 15(1) if no consideration had been paid for the warrants. ...

9 December 2010 Internal T.I. 2010-0371741I7 F- Automobiles mises à la disposition des employés-- summary under Paragraph 6(1)(e) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(e) employer-provided automobile to attend occasional off-site meetings did not generate a benefit In finding that occasional use of an employer-provided automobile for meetings at locations away from the employee’s usual place of work did not give rise to a taxable benefit, the Directorate applied the principles that: [W]here an employee, at the employer's request or with the employer's permission, travels directly from the employee’s home to a place other than the employer's place of business where the employee is ordinarily required to report or to return to the employee’s home, it is considered that such travel is not for personal purposes. ...

CRA responded: Where, pursuant to the specific provisions of an employment contract, an employee receives a payment in lieu of compensation for a period of reasonable notice of termination of employment, this payment is normally considered to be income from employment. … [I]n the majority of circumstances, the compensation paid by the employer under C.C.Q Article 2092. appears to be to compensate for a prejudice caused by the absence of notice. ...