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Recommendation In light of the recent jurisprudence referred to above, it is our opinion that, for purposes of computing safe income on hand, the ARTC should be considered, in substance, a reduction or refund of the ACR. ...

We have considered the application of subsections 70(1) and (2) of the Income Tax Act since these are the only provisions that could possibly result in the pay equity wage adjustment being included in a deceased person's income. ...

However, the deduction is available only where it cannot reasonably be considered that one of the main reasons that the obligation became a parked obligation was to have this subsection apply at a subsequent time. ...

Where an amount described in subsection 181.2(3) is reflected in the notes to the financial statements, it may be considered in assessing the amount subject to tax under Part I.3. ...

4) Are "designated limited partnerships" considered foreign property for purposes of subsection 206(2) of the Act? ...

The expressions "in connection with" and "with respect to" are considered to have very broad meanings such that the activities described in (a) to (f) above would appear to be qualifying activities. ...

Proposed subsection 247(1.1) For the purpose of this memo, we have not considered what impact, if any, that proposed new subsection 247(1.1) might have on the conclusions contained herein. ...

With respect to the facts of this particular situation, if 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 XXXXXXXXXX US shares, it is our view that the Taxpayer’s late-filed designation request could be considered. ...

Medical practitioners for the purposes of the DTC While subsection 118.4(2) describes the requirements for a person to be considered a medical practitioner for purposes of sections 118.2 and 118.3 (among others) – namely, the requirement to consider the relevant provincial legislation – specific rules in section 118.3 allow only certain categories of medical practitioners to certify that an individual has a severe and prolonged impairment in physical or mental functions for the purposes of the DTC. ...

As a result, for purposes of the calculation of Part XII.6 tax, the PBC will be considered to have incurred $3M of CEE in January of 2020 and $2M of CEE in July of 2020. ...