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Ss. 93.1(5) and (6) could only apply to such interest if, pursuant to the coming-into-force (CIF) provision for ss. 93.1(5) and (6) (which otherwise applied only to the 2013 and subsequent taxation years), it could be considered that the taxpayer (USP) had “elected[ed] in writing” and timely “file[d] the election with the Minister” to have ss. 93.1(5) and (6) apply to those earlier years. ...

Furthermore, for those who travelled using their own vehicles, a reasonable per-kilometre allowance payable by their employer would not be included in their income pursuant to s. 6(1)(b) by virtue of the exception in s. 6(1)(b)(vii.1), again because such travel would be considered to be in the course of their employment. ...

Where an amount is deducted under s. 111(1)(a) for a particular taxation year in respect of a subsequent year's non-capital loss for a subsequent taxation year, (a) which instalment method should be used, and (b) should previously applied non-capital losses from subsequent years be considered, in recalculating a functional currency reporter's taxes payable (or refund) for the particular taxation year? ...

. … Paragraph XXIX-A(3)…[inter alia requires:] …The item of income is derived from the source state (Canada) in connection with or incidental to that (US) trade or business (including any such income derived directly or indirectly by that resident person (US person) through one or more other persons that are residents of the source state (Canada)) ("Connected Test") …[I]nterest paid or credited by a Canadian resident to a US person might be considered "derived in connection with" a US active business in the following circumstances: the interest is paid or credited in respect of an account payable issued by [sic] the US person in the course of carrying on its US active business, the interest payments are in respect of borrowed money used for the purpose of earning income from a business carried on in Canada that is upstream, downstream or parallel to the US active business ("Canadian-Connected Business"), or the interest payments are funded out of the cash flow from such a Canadian-Connected Business. ...

After noting that the date of disposition of the FORP partnership interest was either 6 above by virtue of s. 98(2), or the dissolution date in 7 above, the Directorate stated: [A] partnership interest held by a foreign affiliate of a taxpayer will be considered to be excluded property when the partnership would be a foreign affiliate of the taxpayer when the deeming rules in paragraphs (d) and (e) in the definition of “excluded property” are applied and if substantially all of the FMV of the property of the partnership itself satisfies the excluded property definition. … [I]n determining whether [NR1’s] partnership interest is excluded property … any assets held by the partnership on which income was or would be recharacterized as active would qualify as excluded property under paragraph (c). ...