| 2021-04-14 |
7 October 2020 APFF Roundtable Q. 15, 2020-0852271C6 F - Corporate attribution rules |
Income Tax Act - Section 74.4 - Subsection 74.4(2) |
s. 74.4(2) could apply to a s. 51 estate freeze-style reorganization by two spouses in favour of two discretionary trusts for them and their spouse |
| 7 October 2020 APFF Roundtable Q. 16, 2020-0867071C6 F - APFF Q.16 - Withholding tax on swap payment |
Income Tax Act - Section 16 - Subsection 16(1) |
interest is no longer imputed on mismatched cross-border swap payments |
| Income Tax Act - Section 9 - Capital Gain vs. Profit - Swaps |
all amounts payable or receivable under a swap are on income account |
| 7 October 2020 APFF Roundtable Q. 17, 2020-0845821C6 F - Part IV tax and trust |
Income Tax Act - 101-110 - Section 104 - Subsection 104(19) |
various applications of proposition that an s. 104(19) designation is not effective until the trust’s year end |
| Income Tax Act - Section 186 - Subsection 186(2) |
s. 104(13), unlike s. 104(19), can apply contemporaneously with a trust dividend distribution, and ss. 186(2) and 251(1)(b) can apply synergistically |
| Income Tax Act - 101-110 - Section 104 - Subsection 104(24) |
under the ordinary meaning of payable, an amount is payable at a time if it is paid then |
| 2009-01-16 |
7 January 2009 External T.I. 2008-0286111E5 F - 88(1)d) and 87(11)-Late-filed designation |
Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) |
late designation generally permitted where pro rata bump and no retroactive tax planning |
| 8 January 2009 Internal T.I. 2008-0299371I7 F - Montant pour enfant |
Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b.1) |
separated spouse with joint custody not able to claim under s. 118(1)(b.1) because in a new common-law relationship – other spouse could |
| 2008-10-10 |
26 September 2008 Internal T.I. 2008-0281111I7 F - Salaires admissibles - CICEA |
Income Tax Act - Section 127 - Subsection 127(9) - Eligible Apprentice |
wages of apprentice carpenter ineligible to the extent related to renovation rather than new construction |
| 2008-08-22 |
12 August 2008 External T.I. 2008-0278401E5 F - Pension alimentaire |
Income Tax Act - Section 60 - Paragraph 60(b) |
support payments to fiancée living abroad with her children were not deductible |
| 13 August 2008 External T.I. 2008-0286341E5 F - Pension d'invalidité reçue de la GRC |
Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(i) |
pension under s. 11(2) of the RCMP Superannuation Act would not be exempt |
| Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(d) |
RCMP disability pension would not fall within s. 81(1)(d) |
| 2008-08-01 |
25 July 2008 External T.I. 2008-0284861E5 F - Bourse post-doctorale |
Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) |
post-doctoral fellowship recognized under s. 56(1)(n) rather than (o), as the research was merely a means to furtherance of academic career |
| 2008-07-25 |
18 July 2008 External T.I. 2008-0271211E5 F - Fiducie de santé et de bien-être |
Income Tax Act - Section 248 - Subsection 248(1) - Private Health Services Plan |
PHSP can include a self-insured plan |
| 15 July 2008 External T.I. 2008-0275471E5 F - Société de personnes/Ajustement au PBR |
Income Tax Act - Section 99 - Subsection 99(1) |
CRA was prepared to rule to avoid double taxation problem prior to the s. 99(1) amendment |
| Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) |
CRA intent to avoid double taxation from untimely basis adjustment for earned income |
| 15 July 2008 External T.I. 2008-0278971E5 F - Feuillet T1204 |
Income Tax Regulations - Regulation 237 - Subsection 237(2) |
no T2014 slips required where the recipients did not have a contract with the federal government |
| 15 July 2008 External T.I. 2008-0279271E5 F - Frais de déménagement en cas de faillite |
Income Tax Act - Section 128 - Subsection 128(2) |
as s. 128 is a complete code not covering moving expenses, an individual could deduct moving expenses incurred in the stub pre-bankruptcy year from bankruptcy year income |
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