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CRA "did not want plans to be considered offside on the basis of nominal or incidental non-METC coverage," and this change "provides more flexibility in designing plans to handle incidental or nominal non-METC expenses. ...

26 May 2016 Alberta CPA Roundtable, 2016-0645001C6- Failure to file Form T1135-- summary under Subsection 162(7) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(7) failure to file a T1135 may not indicate carelessness or neglect CRA considered that a s. 162(7) penalty for failure to file a T1135 form can be assessed beyond the normal reassessment period (or, under s. 152(4)(b.2), beyond the normal reassessment period plus three years where the taxpayer did not report income from specified foreign property in the relevant return) but, in such a case, CRA would have to “prove” that “although that error may have been made in good faith, it was an error that a prudent and conscientious person would not have made.” ...

(f) of the s. 248(1) “cost amount” definition referenced “cost”, CRA stated: [T]he "adjusted cost basis" of a holder's interest in a life insurance policy, as defined in subsection 148(9), can generally be considered a reasonable estimate of the cost of the property for the purposes of the application of the rules of section 233.3. ...

Furthermore, a "disposition made in accordance with a will, accompanied by-laws or the terms and conditions of a share redeemable by mutual agreement or at the pleasure of the holder, is not considered made in accordance with an agreement in writing. ...

CRA considered that the context and purpose of the income attribution rules: favours a more restrictive interpretation of the word "paid", according to which the issuance of a note, although irrevocable, unrestricted and payable on demand, does not satisfy the requirement provided for in those [provisions]. ...

The advances received by the corporation from the purchaser generally would not be considered to be assets used principally in active business carried on primarily by the corporation, with the result that if such cash exceeded 50% of the total value of the target corporation's assets, its shares would cease to qualify. ...

17 June 2004 IFA Roundtable Q. 2, 2004-0072381C6- Flow-through treaty benefits partnership-- summary under Article 1 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 1 CRA is revisiting the issue whether a partner resident in a treaty country should receive the benefits of a tax treaty between Canada and that treaty country where the partner is a member of a partnership formed in Canada which is transparent for Canadian tax purposes but is considered to be a foreign corporation for purposes of the treaty country's tax system, so that the partners are not actually taxable on the partnership income in the treaty country. ...

., auto repairs and home renovations) the revenue from the goods will be considered. ...

CRA noted that this was similar to Example 9 of CRA’s split-income guidelines, and stated that they both could be considered to be actively engaged in the business – but indicated that this was a question of fact. ...

., under s. 104(24)) that it was payable for the purposes of s. 104(6), and that “[i]f the amount cannot be paid in accordance with the terms of the trust and the relevant trust law, the amount cannot be considered to have become payable for the purposes of subsections 104(6) and (13).” ...