In a June 3, 2004 Technical Interpretation, CRA notes that when a taxpayer converts a principal residence to an income-producing use, the taxpayer may, within limits, elect to defer recognition of any gain to a later year.

In a 2004 Advance Income Tax Ruling, six non-arm's length individuals were employee/shareholders of a corporation. The corporation wishes to sell all of the assets and then wind up.

CRA Ruled that a retiring allowance paid to each employee within prescribed limits is deductible to the corporation and eligible for a rollover by the employees to a Registered Retirement Savings Plan.

In a June 21, 2004 Federal Court of Appeal case, the taxpayer had an October 31 yearend and, purchased a "new fleet" of cars to replace the “old fleet” as at October 31.

However, the "old fleet" remained in the ownership of the taxpayer until November 1. Therefore, CCA was allowed on both the “old fleet” and the “new fleet” at the October 31 yearend.