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Consequently, if the holder of the TFSA owns directly or indirectly 10% or more of any class of shares of the MIC, the investment in the MIC will be considered a prohibited investment for the TFSA. ... Under proposed amendments to the definition of "advantage" in subsection 207.01(1) contained in Bill C-47, such income will be considered an advantage and thus subject to a 100% tax under section 207.05 of the Act. ...

However, where an amount of remuneration is paid to a registered charity the particular individual might be entitled to claim a non-refundable tax credit under subsection 118.1(3) of the Act provided the amount is considered to be a charitable gift. As described in Interpretation Bulletins IT-110R3, Gifts and Official Donation Receipts and IT-297R2, Gifts in Kind to Charity and Others, a charitable gift will generally be considered to have been made where the transfer is voluntary and is made without expectation of return by the donor. ...

XXXXXXXXXX 2010-037826 Andrea Boyle, CGA September 14, 2010 Dear XXXXXXXXXX: Re: Expropriation I am writing in reply to your letter dated May 31, 2010, in which you asked whether the purchase of a rental property by XXXXXXXXXX would be considered to be an expropriation and consequently, whether the recognition of a capital gain on the disposal could be deferred if, before the end of the second taxation year following the initial year, a capital property is acquired that is a replacement property for the former property. ... Generally, a particular property would only be considered a replacement property if it is acquired to replace the former property and there is a causal relationship between its acquisition and the disposition of the former property; the particular property is acquired and used for a use that is the same or similar to the use to which the former was put; and, where the former property was a taxable Canadian property, the particular depreciable or capital property is also a taxable Canadian property. ...

It is our view that if you establish a temporary base in a place other than your home, then you may be considered to be temporarily residing in that place (sojourning) rather than traveling. ... In our view however, the continuation of salary for the period of leave in the taxpayer's circumstances cannot be considered as scholarship or bursary income. ...

26 April 2010 External T.I. 2010-0363521E5- Northern residents deduction Unedited CRA Tags 110.7, 248(1) Principal Issues: Whether an employee who works and lives in a prescribed northern zone in employer provided accommodation for a schedule of fourteen days on and fourteen days off and maintains a principal residence outside any prescribed northern zone, would be considered to have resided in a prescribed northern zone for a period of more than six consecutive months for purposes of the northern residents deduction. ... As discussed in the instructions on Form T2222, in determining whether an individual has lived in a prescribed zone for the qualifying period, in general, where an employee resides in a prescribed zone on a permanent basis, the continuity of residency for a qualifying period is not considered to be broken or interrupted by short-term absences, such as vacations. ...

More specifically, you have enquired whether your short term disability plan (the "Plan") meets the definition of a wage loss replacement plan ("WLRP") under the Income Tax Act (the "Act') and whether payments from the Plan are considered pensionable earnings for CPP purposes. ... This type of arrangement will not be considered a WLRP unless the plan is based on insurance principles. ...

Consequently, if the holder of the TFSA owns directly or indirectly 10% or more of any class of shares of the MIC, the investment in the MIC will be considered a prohibited investment for the TFSA. ... Under proposed amendments to the definition of "advantage" in subsection 207.01(1) contained in Bill C-47, such income will be considered an advantage and thus subject to a 100% tax under section 207.05 of the Act. ...

To be considered a replacement property, a particular property must meet all the requirements outlined in the definition in subsections 13(4.1) (for the rules in subsection 13(4) for depreciable property) and 44(5) (for the rules in section 44 for capital property) of the Act. ... Generally, a property is considered a replacement property, if it is acquired to replace the former property and there is a causal relationship between its acquisition and the disposition of the former property. ...

20 December 2010 External T.I. 2010-0385151E5- Business or Property Income Unedited CRA Tags 9; 248(1) "farming"; 3 Principal Issues: Whether the income from a rental activity is considered business income or income from property. ... In determining whether the revenue from the rental of real property gives rise to income from a business of farming or from property, other factors may have to be considered such as whether the rental is on an ongoing basis and whether the farming operation to which the rental relates is discontinued, or simply temporarily suspended. ...

In Interpretation Bulletin IT-339R2, Meaning of private health services plan [1988 and subsequent taxation years], the Canada Revenue Agency has set out the requirements that must be met in order for a plan to be considered a PHSP. ... As indicated in paragraph 7 of IT-339R2, an arrangement where an employer reimburses its employees for the cost of medical care or hospital care may be considered a PHSP where the employer is obligated under the employment contract to reimburse such expenses incurred by the employees or their dependants. ...