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The payment would not be considered to be a retiring allowance if the employee were rehired by his employer or an affiliate shortly after the lay-off, and this was foreseeable at the time of the lay-off. ...

.- Q18-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share Where land is acquired and a building is constructed for use in an active business which will be expanding or relocating to the new facility, and the new facility is in fact used in the active business within a reasonable period of time after completion, the land and building will be considered to have been used in an active business from the date of acquisition of the land to the date of occupancy. ...

The policy would not normally be considered to be an asset used in an active business carried on by the corporation where the life insurance proceeds are to be distributed by the corporation as a dividend or to fund a buy-sell agreement. ...

4 June 2012 Interpretation Case No. 131194-- summary under Paragraph (l) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (l) taxable loan broker fees from car dealers The fees earned by a loan broker from car dealers would generally be considered predominantly administration services of obtaining credit information from purchaser, completing the loan application, explaining loan terms to purchaser, preparing contracts for the dealer, submitting the completed contracts to lending institutions, and would not be a financial service under paragraph (l) of the definition of financial service. ...

9 May 1990 Meeting (October 1990 Access Letter, ¶1474)-- summary under Subsection 248(10) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(10) "If at the time of the 'butterfly' reorganization the shareholders had formed the intention to sell their shares, and their shares are eventually sold, the reorganization and the ultimate sale will be considered to form part of the same series even though at the time of the reorganization the shareholders either had not determined all of the important elements of the subsequent sale- such as, for example, the identity of the purchaser or the purchase price and terms of payment- or lacked the ability to implement the subsequent sale. ...

A car allowance generally (but not always) will be considered reasonable if it does not exceed the 27 cents/21 cents amount. ...

Where it is considered that a part of a debt is collectible and a part is not, a portion only of the debt may be viewed as a bad debt. ...

Transactions which are structured as management agreements or licences and under the terms of which a lessee/lessor relationship does not exist would not generally be considered as leases for income tax purposes. ...

. … For this reason, one is to assume that the expenses would need to be submitted to the insurance company before the amount can be considered by the Canada Revenue Agency…. ...

Round Table, Q. 34-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) Transactions, whereby an individual took advantage of the fact that he had preferred shares of a holding company with a fair market value and ACB (of $400,000) corresponding to the safe income and fair market value of shares of an operating company, in order to effect a disposition of the shares of Opco to a third-party purchaser on a tax-free basis, were considered to represent an abuse given that former s. 247(1) would have applied to such transactions and given that if the holding company had sold its shares of the operating company directly, the individual would have realized the proceeds of disposition by way of a taxable dividend. ...