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Since IFRS reporting is considered Canadian GAAP, it is appropriate to use “Total comprehensive income”, representing a combination of profit or loss and other comprehensive income (“OCI”), as a starting point for computing ANI/ANL [adjusted net income/adjusted net loss]. ...

Respecting the Maturity Payment, it did not satisfy the s. 20(1)(f) wording, as a “forward transaction cannot be considered to be any bond, debenture, bill, note, mortgage, hypothecary claim or similar obligation” (Federated Co-op was cited in this regard). ...

Thus, for the purposes of section 116, all shares disposed of must be considered, not just those disposed of for cash consideration. ...

The CRA's administrative position on the pick-up point is that a bus stop near the driver's home is not considered a pick-up point. ...

After noting that the loan was assistance for the purposes of s. 12(1)(x) and the definition thereof in s. 125.4(1), and reduced Prod Co's "labour expenditure" as defined in s. 125.4(3) (and after also finding that the funding would not have been “assistance” under s. 125.4(1) if made in the form of a share subscription), the Directorate considered whether there would be such assistance if M Co converted its loan into shares at the end of the production, and stated: Subject to the possible application of paragraph 80(2)(g.1), there will be a debt settlement if the FMV of the shares is less than the amount of the loan. ...

. … We are of the view that the Benefit can be considered to be based on the needs of a beneficiary unit (roughly a family). ...

As such, in the Example, to the extent that a portion of the interest paid to FALuxco by MLP is considered to be paid by a member that is not described in subclause 95(2)(a)(ii)(B)(I), that portion should not be recharacterized as income from an active business since it would not be so recharacterized if it had been paid directly by that member. ...

Similarly, if Opco receives a dividend from Finco and then pays a dividend to Canco in the taxation year in which Opco becomes liable to pay the tax under subsection 160(1) or a later year, then Opco would be considered the “transferor” of the property under subsection 160(1) and Canco, as the transferee of the property, would be jointly liable to the tax with Opco, to the extent of the amount of the dividend or the amount of the tax, whichever is the lesser. ...

In response to a query as to whether Part XIII withholding tax applies to the Accrued Interest pursuant to paragraph 212(1)(b), the Directorate indicated its “preliminary conclusion” that there was a novation of the Partnership’s Loan obligation and then stated: [A]t the time of this novation, the Partnership would be considered to have made a payment or credit in kind of the Accrued Interest to the Creditor Affiliate by delivering the Debtor Affiliate’s covenant to make the payments under the Loan agreement to the Creditor Affiliate. ...

In rejecting the second, it adopted a previous statement that “the subparagraph 75(2)(a)(i) condition would not be considered satisfied from the potential acquisition of the property from the spouse's estate in accordance with the spouse's will. ...