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If the capital cost of the property exceeds the elected proceeds, for the purposes of sections 13 and 20 and any regulations made under paragraph 20(1)(a), the capital cost of the property will be deemed to be the capital cost immediately before the deemed disposition, and the excess will be considered to have been allowed to the corporation as capital cost allowance. ...

This position is supported at paragraph 3 of IT-417R where it states      "... it is considered that the Income Tax Act always required and continues to require that all costs that could clearly be related to future periods be expensed in those periods, if they are material and if failure to defer the expense would distort the net profit not only of the year during which the expense was incurred but also of the subsequent year or years to which the benefit relates. ...

As we will explain later, this may cause surprise, uncertainty and prejudice to the Minister and therefore the decision in Trynor cannot be considered as supporting the taxpayer's position in this case. ...

MNR [1985] 2 CTC 2383 (TCC) the court considered a situation in which a closely held corporation had, throughout most of a particular year, made weekly salary payments to its president, who was also the majority shareholder.  ...

In this regard, 24(1) in their letter of November 26, 1988 made reference to fixed and circulating capital, concepts which were considered in the Canada Permanent case.  ...

Generally, a change in an employee’s circumstances is considered to take place when there is a change that impacts the application of the Guidelines. ...

In the situations described above, the issue as to whether the payments made by the limited partnerships to XXXXXXXXXX that were treated as loans by the parties can be considered to be bona fide loans for the application of paragraph 96(2.2)(c) and subparagraph 53(2)(c)(v) (rather than distributions) should be determined based on the laws of the Province of Ontario. ...

As noted in Income Tax Technical News No. 38 (“ITTN 38”) and document 2008-0289461I7, a separate legal personality is no longer considered a distinctive feature of corporations alone, and is not in itself a determinative characteristic. ...

A benefit under subsection 15(1), while not specifically defined in the Act, would include just about any payment, appropriation of property or advantage conferred on the shareholder by the corporation. 2 As indicated in paragraph 5 of Interpretation Bulletin IT-432R2, a benefit will normally not be considered to have been conferred on a shareholder where the transaction is a bona fide business transaction. ...

Similar calculations should be made to determine what portion of any stock option benefit realized by the US Employee in the 2011 calendar year is considered as being derived from employment exercised in Canada in that year. ... In our view, the corporation that has agreed to sell or issue the shares to the employee (in this case, Canco) will be considered to be the “payer” of the stock option benefit for purposes of paragraph 153(1)(a) (and will be responsible for the normal withholding), unless it receives reimbursement, in whole or in part, either directly or indirectly, in respect of the benefit. ...