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CRA considered this to be the appropriate result: there would have been the same $300 loss had Canco directly owned FA ($3,000 dividend- $3,000 s. 113(1) deduction- $300 interest expense). ...

CRA indicated that it considered the phrase “merged or combined” in s. 40(3.5)(c)(i) as encompassing a winding-up or liquidation. ...

CRA referenced Consolidated Glass as indicating that the concept of a sustained loss is one of absolute and irrevocable finality, and that foreign exchange gains or losses respecting a debt obligation are considered to realized or sustained only on the settlement or extinguishment of the debt, i.e., on their repayment or legal novation or legal rescission and substitution, and would also result in the creditor realizing a corresponding foreign exchange gain or loss. ...

., selling life insurance or providing investment products) would be considered to be engaged in the provision of services? ...

It first must be considered to be carrying on a business. Would the income generated by Realtyco from the six buildings qualify as “income of the corporation for the year from an active business” for purposes of s. 125(1)(a)? ...

5 October 2018 APFF Roundtable Q. 16, 2018-0768871C6 F- Dépenses de bureau à domicile et d’automobile-- summary under Incurring of Expense Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense payment of expenses of taxpayer by another does not preclude “incurring” by taxpayer Respecting the deductibility of home office and automobile expense of an independent contractor where such taxpayer owns the property and another person (who might be a spouse) pays such expenses, CRA stated: For an expense to be considered to have been incurred for the purposes of paragraph 18(1)(a), it is not necessary that the expense be paid by the person incurring the expense. ...

10 October 2003 Roundtable, 2003-0037135 F- CONTRATS DE RENTE VIAGERE-- summary under Subsection 301(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 301- Subsection 301(1) annuity did not qualify as a "life annuity" where payments made to a corporation Where an annuity may be payable during the lifetime of an individual, who may be an employee or shareholder of a corporation, and the corporation is the purchaser and owner of the annuity contract and is also the beneficiary of the annuity payments, will the annuity contract be considered a life annuity contract within the meaning of Reg. 301? ...

At this point, a taxpayer's venture will be reviewed and criteria, including those set down in Moldowan, will be considered in determining if the taxpayer intends to carry on an activity for profit and the overall evidence supports that intention. … If a taxpayer is motivated by tax considerations when he or she enters into a business or property venture, this will not detract from the venture's commercial nature or characterization as a source of income under the Act. ...

Factors that may be considered are the taxpayer’s past level of compliance and the existence of large unexplained tax reserves. ...

Generally, the acquisitions and dispositions during the normal course of business would not be considered acquisitions or dispositions of separate businesses. ...