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He considered that the complainant had not intended to make a profit in this particular situation and that she would have taken care of her daughter even if she had not received any money for that care. ...

After finding that the tuition reimbursement amounts otherwise would have been employment income pursuant to s. 6(3), but in finding that there was not taxable benefit, the Directorate stated: [T]raining courses that are taken to maintain or improve skills related to the employer's business are generally considered to be of primary benefit to the employer if it is reasonable to expect that the employee will return to employment for a significant period of time after the course is completed. ...

In finding that CCRA should not allow such carryforward, the Directorate stated: Since Parliament used the term "deducted" as opposed to "deductible" in paragraph 111(3)(a), we are of the view that any portion of the loss actually deducted by the Corporation in previous taxation years must be considered, even if the taxpayer deducted an amount in error [citing Dominion of Canada General Insurance]. ...

3 May 2001 Internal T.I. 2001-0081837 F- BILLET CONVERTIBLES PRINCIPAL-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) corporation was considered to have paid an amount on conversion of convertible notes equal to their face amount and stated capital of the issued shares The corporation issued convertible notes whose principal was exchangeable into a specified number of no par value common shares, on the basis of $X (or on maturity, $Y) of face value of the note for each common shares. ...

. … [I]f [instead] the GST/HST collected and remitted is in respect of a benefit included in a shareholder's income under subsection 15(1) … the corporation cannot deduct it in computing its income from a business or property since it would not be considered to have been incurred for the purpose of earning its income from the business or property. ...

Although the lease prepayment received by the taxpayer from the SPV would be considered to be an "advance", it would not give rise to capital for LCT purposes because no amount would be reflected in the corporation's balance sheet in respect of those amounts. ...

Although accepting, based on the line of cases culminating in Teleglobe, that the amount paid by the corporation on the debentures’ repayment on conversion was equal to the shares’ stated capital, the Directorate considered that the stated capital of such shares was the amount stated to be paid on conversion in the trust indenture governing the conversion, namely, the face amount of the debentures, which also equaled the amount shown in the corporation’s financial statements as the shares’ stated capital. ...

Although accepting, based on the line of cases culminating in Teleglobe, that the amount paid by the corporation on the debentures’ repayment on conversion was equal to the shares’ stated capital, the Directorate considered that the stated capital of such shares was the amount stated to be paid on conversion in the trust indenture governing the conversion, namely, the face amount of the debentures, which also equaled the amount shown in the corporation’s financial statements as the shares’ stated capital. ...

The Directorate noted that the ITC and ITR amounts would be considered government assistance pursuant to s. 248(16) (regarding the ITCs) and s. 12(1)(x) (regarding both), so that the taxpayer could elect pursuant to s. 12(2.2) to reduce such expenditures, and so that, pursuant to s. 12(1)(x)(vii), there would be no income inclusion. ...

The Directorate noted that the ITC and ITR amounts would be considered government assistance pursuant to s. 248(16) (regarding the ITCs) and s. 12(1)(x) (regarding both), so that the taxpayer could elect pursuant to s. 12(2.2) to reduce such expenditures, and so that, pursuant to s. 12(1)(x)(vii), there would be no income inclusion. ...