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. … [T]he following should be considered in particular: the use that is actually made of the property in the course of the various activities of the FA, the income from the use or possession of the property, the intention of the FA with respect to the use and holding of the property, the terms and conditions of ownership of the property, the nature of the activities of the FA and current practices in the particular industrial sector. ...

Thus … a corporation that carries on a PSB will be able to deduct the salaries of the two trucker spouses if the two trucker spouses are considered to be incorporated employees of the corporation. ...

. … The following are some elements that may be considered by the CRA in determining the "normal rate of return" in a particular situation: The rate of return that the corporation could earn on the capital invested to acquire the property made available to its shareholder; The rate of interest on a loan that the shareholder would have received from a person with whom the shareholder deals at arm's length if the shareholder had borrowed personally to acquire the property made available to the shareholder. ...

As well, pursuant to paragraph 7(1.3)(a), "a taxpayer holding both deferral and non-deferral securities is considered to dispose of the non-deferral securities first.” … Depending on the circumstances, the application of the presumptions in subsection 7(1.3) could result in the requirement of paragraph 110(1)(d.01) in respect of the acquisition of securities in the year of disposition not being satisfied. ...

Where the matter instead has not been previously considered by the GAAR Committee, and the GAAR is likely going to be an assessment position, the TSO will refer the matter to Headquarters prior to issuing the proposal letter – so that it would generally only issue a proposal letter if Headquarters recommends GAAR’s application. ...

29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6- Investment management fees-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) bearing of RRSP or TFSA fees by the annuitant or holder typically will be subject to the 100% advantage tax, effective 2018 CRA considers that the payment of fees for investment management of an RRSP, RRIF or TFSA by the plan annuitant or holder typically will be considered to be an “advantage” for Part XI.01 purposes (i.e., giving rise to a tax equal to 100% of the fee amount). ...

CRA responded: [A]n immovable is normally considered to be a single and sole property unless it is legally subdivided into two or more separate properties. … [T]he relation between the use regularly made by the taxpayer of the property for gaining or producing income and the use regularly made of the property for other purposes had not changed at that time [of the move]. ...

CRA responded: Where an expense is incurred in respect of all of a property of which only a part is used for the purpose of gaining or producing income, the expense will be apportioned between the two parts of the property so that only the part of the expense that can reasonably be considered to have been incurred in order to gain or produce income may be deducted. ...

However, a rate different from that prescribed may be considered reasonable in light of the particular facts of a situation. … [T]he CRA does not have a specific policy on per-kilometre allowances for an electric motor vehicle. ...

In other words, the child must live with the parent on the days in question, as opposed to a parent who would only have visitation rights while the child was considered to be living with the other parent. ...