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[T]hus...the interests of Canco in SEC and SENC cannot be considered as immovable property…. ... Consequently, the Canadian immovable properties which are held by means of SEC and SENC should be considered as being directly held by Canco to the extent of its interests in them... ...

7 March 2013 Internal T.I. 2011-0428491I7- Paragraph 149(1)(c)-- summary under Paragraph 149(1)(c) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(c) policy guidelines re public body A municipal body is typically considered to be a body established or exercising a power under a municipal act or a similar statute of a province or territory with respect to governing the affairs or purposes of a geographic area and is accountable to those governed by it. ... Further, providing a key service traditionally offered by the provinces or territories such as social services, overseeing of the environment, health services, and education is generally considered to constitute performing a function of government. ...

Since "stipend and remuneration" are considered to refer to gross (not net) amounts under the definition of "office", unreimbursed expenses (whether or not the nature or quantum of the expenses is known in advance by the individual) are not considered when determining whether a particular amount is fixed or ascertainable. ...

5 October 2015 Internal T.I. 2014-0522241I7- T1135: Mineral rights situated outside of Canada-- summary under Specified Foreign Property Summary Under Tax Topics- Income Tax Act- Section 233.3- Subsection 233.3(1)- Specified Foreign Property foreign mineral right is tangible property Is the right to mine minerals situated outside of Canada considered “real property” for T1135 reporting purposes, and if so how is the “cost amount” for such property determined? ... As such…the right… would be considered tangible property that is specified foreign property for purposes of section 233.3…. ...

In concluding that the “TP would likely be considered a salary advance which should be included in the employees’ income in the year it is received,” the Directorate stated: [W]here an employer makes a payment to an employee that is an advance on account of the employee’s future earnings, the amount received is generally not considered to be a loan to which subsection 80.4(1)… applies. … Normally, an employee is not required to repay a salary advance as long as he or she continues to perform the services (i.e., remains employed). ...

In addition, you informed us that the Equipment used by a non-resident corporation in connection with the performances by an artist were considered by the TSO to be of sufficient importance to constitute a permanent establishment for the purposes of Reg. 400(2)(e) at each of the venues where it mounted performances. Initially, the Directorate considered that “the equipment or machinery must be used either for a period of more than 30 consecutive days per site or project or for a period of more than 90 consecutive days within a 12-month period for all projects,” so that the venues did not qualify as PEs. ...

5 March 2010 Internal T.I. 2009-0346261I7 F- Minimisation des pertes-- summary under Subsection 104(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(2) the trust and trustees both considered to be an individual respecting the corpus and thus to own it Before concluding that a testamentary trust can qualify as an estate beneficiary for s. 112(3.2)(b) purposes, the Directorate stated: [A]lthough under civil law a trust does not in itself constitute a separate legal entity, Parliament has chosen, for the purposes of applying the Act, to disregard these legal effects and instead treat the trust as a separate tax entity with ownership of the property it holds. ... The combined application of subsections (1) and (2) of section 104 means that, for the purposes of the Act, both the trust and the trustee(s) (or executor(s)) of the trust may be considered to be an individual in respect of the trust property and thus to own or control the trust property, regardless of the applicable private law. ...

30 November 2009 Internal T.I. 2009-0344051I7 F- Pénalités visées par 162(7), (7.01) et (7.02)-- summary under Subsection 162(7.01) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(7.01) ss. 162(7) and (7.01) (and, where relevant, (7.02)) apply to each of T5003 Summary and T5005 slips Are the T5003 "Tax Shelter Information" return and the T5003 "Statement of Tax Shelter Information" slips considered to be separate information returns and, if so, does s. 162(7) apply to the T5003 summary return while s. 162(7.01) applies to the slips? The Directorate first stated: Although the T5003 "Tax Shelter Information Return" and the T5003 "Statement of Tax Shelter Information" slips are considered interdependent … each summary and slip is a separate information return. ...

The Directorate stated: In general … there is no taxable benefit [where]: the value of the meal or meal allowance is reasonable: in general, an amount up to $17 is considered reasonable; The employee works two or more hours of overtime right before or right after their scheduled hours of work. ... In general, less than three times a week will be considered infrequent or occasional. ...

CRA responded: [T]he portion of the amount paid… in respect of the maximum…20,,, days sick leave in the Reserve at the time of retirement or in respect of the loss of employment may be considered a retiring allowance. However, the portion of the amount paid to the employee that is equivalent to the number of days of sick leave that exceeds twenty (20) days and would otherwise be paid to the employee during the month of December… is usually considered to be employment income. ...