Income Tax Severed Letters - 2017-08-16

Technical Interpretation - External

Unedited CRA Tags: 
54

Principal Issues: A fire destroys a principal residence and insurance proceeds are received. If the land is sold in a subsequent year, can any of the gain be sheltered by the principal residence exemption?

Position: Possibly.

Reasons: See below.

Unedited CRA Tags: 
9(1)

Principal Issues: Whether an individual can earn commission income through a corporation.

Position: Question of fact. Possibly yes.

Reasons: See below.

Unedited CRA Tags: 
56(1)(u); 110(1)(f); Reg 233(2)

Principal Issues: Whether payments made under the Ontario Basic Income Pilot program are considered social assistance?

Position: Most likely yes.

Reasons: They are based on an income test.