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Opinion It is our view that debt incurred to gift to qualified donees cannot be considered debt incurred in the course of administering charitable activities for purposes of paragraph 149.1(4)(d). ...

31 August 2020 Internal T.I. 2020-0851811I7- US Economic Impact Payment Principal Issues: Whether amounts received by a permanent resident of Canada under the US Economic Income Payment program would be included in income Position: Likely no Reasons: The amount is considered an advanced payment of a 2020 refundable tax credit, and therefore is likely not income from a source under the Income Tax Act. ...

However, it is the Canada Revenue Agency’s (CRA) general position that this requirement may also be considered to have been satisfied where it was tacitly understood by the employee and the employer that such payment was to be made by the employee to carry out the duties of the employment. ...

It is also our understanding that in the sheltered workshop environment the majority of disabled persons are performing activities that are not considered  to be in the nature of work for the purposes of determining whether an employer/employee relationship exists. ...

Where deemed dividends are included in the trust income and it may reasonably be considered that the dividends are part of the beneficiaries' income which has been paid or is payable to them we agree that a designation under subsection 104(19) of the Act may be made by the trust.  ...

Generally, an NPO which holds long-term investments does so to produce income from property or a business, and therefore it could not be considered to be operated exclusively for a purpose other than profit. ...

We note that if the cash will be used in the Taxpayer's normal business cycle, this would not be considered to be offensive. ...

" However, an amount is considered earned and is not in respect of services not rendered if the taxpayer's right to the amount is under no restriction, contractual or otherwise, as to its disposition, use and enjoyment, or the taxpayer's right to the amount is absolute and unconditional. ...

If, for example, the donor was required to donated the proceeds from the sale of the servitude to the 24(1) the gift would no longer be considered voluntary and a charitable donation receipt should not be issued. ...

29 August 1989 Internal T.I. 58509 F- Foreign Exchange Loss, Whether Cost of Property Disposition Unedited CRA Tags n/a   August 29, 1989 To: Bilingual Services and Resource Industries Resource Industries Division Section   John Shaw Carole Gouin-Toussaint 957-8968 Director   File No. 5-8509 Subject: 24(1) This is briefing memorandum for our meeting to be held August 30, 1989 with the representatives of 24(1) Issue 21(1)(b) and 24(1) Facts 24(1) Taxpayer's Arguments 24(1) We, at least for the moment, concede that the prepayment penalty is an expense made or incurred for the purpose of making the disposition, but assert that the foreign exchange loss is not, as it is part of the repayment of the loan, which repayment itself, may hardly be considered a cost of disposition of property. ...