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The Directorate went on to indicate that s. 105(2) could apply “to all or part of the expenses actually incurred by Opco that could reasonably be considered to be attributable to the portion of the Immovable occupied by Sister as a place of residence” and that any “portion of the amount that would be included under subsection 105(2) in computing Sister's income may be deducted in computing the trust's income pursuant to paragraph 104(6)(b).” ...

Thus … a corporation with no assets or liabilities at the end of a taxation year (or a corporation with no liabilities at that time) cannot generally be considered insolvent for the purposes of subparagraph 50(1)(b)(iii). ...

The transaction was therefore not a speculative transaction and cannot be considered as an adventure in the nature of trade. ...

On the other hand, income from property that is employed or risked in a corporation's business operations is considered to be active business income. … [T]he Court's judgment had the effect of crystallizing the amount receivable and making it payable to the Taxpayer retroactively from the date of the summons. ...

…[P]aragraph 80(2)(b) will not apply to compound interest if it is not deductible by virtue of paragraph 20(1)(d), being considered unpaid. ...

., from the time of the sale forward, the contribution is considered to have never occurred). ...

. … [F]or U.S. income tax purposes, the Canadian Branch profits of LLC3 are considered to be derived by the first entity in the corporate chain which is not treated as a fiscally transparent entity for U.S. income tax purposes. ...

After quoting from Nassau Walnut to the effect that where the Minister changes the provision under which the taxpayer’s income is computed and the taxpayer then seeks a deduction under the new provision, that request “ does not raise the spectre of retroactive tax planning,” the Directorate then stated that here: [I]f the CRA has the ability to reassess the Taxpayer’s Part I income tax return for year-end #1 pursuant to subparagraph 152(4)(b)(iii) with respect to its disposition of the … US shares … the Taxpayer’s late-filed designation request could be considered. ...

Subsequently to the transactions considered in 2017-0735771I7, ACo transferred its shares of BCo to DCo for consideration including shares of the capital stock of DCo pursuant to subsection 85.1(3) of the Act. ...

However … where a “professional status” is only acknowledged in an organization’s bylaws, the “professional status” would not likely be considered “recognized by statute” …. ...