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S3-F9-C1- Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) bad debt from fraudulent investment scheme 1.43 A taxpayer may claim a deduction for a bad debt pursuant to paragraph 20(1)(p) in the year the fraud is discovered to the extent that investment income purportedly earned from a scheme, that was not considered to have been received or withdrawn by the taxpayer, was previously included in the taxpayer's income. Generally, the year the fraud is discovered is considered to be the year during which the Crown lays charges against the perpetrator of the fraud. … ...

A taxpayer who executes a valid disclaimer (not in favour of any person) of an income interest in a trust will be considered not to have acquired that income interest. ... The taxpayer must include that amount in income pursuant to subsection 106(2). … 1.14 … Pursuant to paragraph 248(8)(c), a release or surrender by a beneficiary with respect to any property that was property of a deceased individual immediately before death, is not considered to be a disposition of the property by the beneficiary. ... Release or surrender for no consideration 1.15 A taxpayer who, for no consideration, validly releases or surrenders, in accordance with the terms of the trust and the relevant provincial law, an income interest in a trust in respect of future payments (amounts not due and payable at the time of the release or surrender) and does not in any manner direct who is entitled to receive the benefits, will not be considered to have received any proceeds of disposition for the purposes of subsection 106(2). ...

In this context, different interests are considered to exist when each party has an independent interest from the other parties to a transaction, notwithstanding the fact that each party may have the same purpose, such as economic gain. ... Partners 1.43 …[W]hen a partner is not in a position to control a partnership and that partner has little or no say in directing the operations of the partnership, it is generally recognized that the partner is dealing at arm's length with the partnership. … 1.44 Partners are not necessarily considered not to deal at arm's length with each other in transactions outside of their partnership activity merely because they are members of the same partnership Shareholders acting in concert 1.53 …[I]f a sufficient number of minority shareholders act in concert in order to direct the affairs of a corporation, they may be considered not to be dealing at arm's length with the corporation. … In a widely-held corporation, the fact that a majority of shareholders vote collectively to take some business action may not, by itself, indicate that those shareholders are acting in concert…. 1.54 [In] situations where closely-held private corporations employ some of the same personnel, occupy the same premises, and to the public eye, appear to be one enterprise…the corporations may be considered not to be dealing with each other at arm's length. ...

S1-F1-C1- Medical Expense Tax Credit-- summary under Subsection 118.2(2.1) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2.1) Procedures that would generally be considered to have a medical or reconstructive purpose include those that would ameliorate a deformity arising from, or directly related to, a congenital abnormality, a personal injury resulting from an accident or trauma, or a disfiguring disease. ... Common procedures the costs of which are generally not considered to be eligible medical expenses because of the application of subsection 118.2(2.1) include: augmentations (such as chin, cheek, lips); filler injections (for removal of wrinkles); liposuction; and teeth whitening. ...

Profit- Commodities, and commodities futures and derivatives Gift by its artistic creator can be of capital property if it was created without resale intention 1.82 When a visual artist creates a work of art with the intention of selling it but instead gifts it to another person, the gift is considered to be a disposition of a property from their inventory. An artist would generally be considered to have made a gift of capital property when the property gifted is property that would not normally be produced and sold in connection with their business. ...

S5-F1-C1- Determining an Individual’s Residence Status-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 1.41 [T]o be considered liable to tax for the purposes of the Residence article of Canada's tax treaties, an individual must be subject to the most comprehensive form of taxation as exists in the relevant country. ... The Queen v Crown Forest Industries Limited, [1995] 2 S.C.R. 802, 95 DTC 5389.... 1.42 An individual does not necessarily have to pay tax to another country in order to be considered liable to tax in that country under paragraph 1 of the Residence article of the tax treaty with Canada. ... In these cases, the CRA will generally accept that an individual is a resident of the other country.... 1.44 [H]olders of a United States Permanent Residence Card (otherwise referred to as a Green Card) are considered to be resident in the United States.... 1.47... ...

Meaning of "paid... for the year" 1.32 …The words, for the year relate to the year for which the taxpayer is liable to pay tax (that is, when it is exigible) to the foreign jurisdiction for the income which is considered to have been earned under the foreign jurisdiction’s tax law, even though the income may not be realized in Canada during the same tax year. Where a foreign country uses a tax year different than the tax year used in Canada, the foreign taxes actually paid must be prorated to match the Canadian tax year. 1.33...Any portion of a taxpayer’s foreign tax which is paid but which will be, or is, refunded to the taxpayer is not considered to be tax paid for the year. ...

The access rights are considered to be part of the capital cost of the road (Class 17) because of paragraph 13(7.5)(c). The capital costs of these rights are considered to be $200,000 and $300,000, respectively. ...

S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subsection 146.2(6) Summary Under Tax Topics- Income Tax Act- Section 146.2- Subsection 146.2(6) Option trading and short selling 1.90 As discussed in ¶ 1.41 and ¶ 1.46, where a registered plan engages in certain option writing strategies or foreign exchange trading, it may be considered to be carrying on a business. ... This decision does not stand for the proposition that the trading of securities in a registered plan will not in any circumstance be considered to be carrying on a business by the plan. ...