Income Tax Severed Letters - 2015-10-21

Technical Interpretation - External

CRA Tags:

Principal Issues: Is a standby charge benefit included in income when an employee is required to use, at all times, an employer's automobile which is emblazoned with the employer's logo, colours and advertising?

Position: Likely yes

Reasons: See response

Technical Interpretation - Internal

CRA Tags:

16 July 2015 Internal T.I. 2015-0590681I7 - Application of paragraph 162(10.1)(e) penalty -- attach -- Subsection 162(10.1)

same date must be used for picking maximum amount

Should the computation of the s. 162(10.1)(e) penalty be based on:

  • Option 1: the highest of all amounts each of which is the total costs of all...

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Principal Issues: How should the total amount subject to penalty be calculated?

Position: It should be the greatest of the total cost amounts of all specified foreign properties per period.

Reasons: Wording of s. 162(10.1)(e)