| 2006-12-29 |
30 October 2006 External T.I. 2006-0170071E5 F - Attribution de revenus - société en commandite |
Income Tax Act - 101-110 - Section 103 - Subsection 103(1) |
allocation of deferred gain to partners, who previously had contributed on a s. 97(2) rollover basis, seemed reasonable |
| 6 October 2006 Roundtable, 2006-0197131C6 F - Police soins de longue durée |
Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(q) |
premiums for policy providing both fixed benefit to cover costs of staying in a long-term care facility and of nursing care, would not qualify |
| 6 October 2006 Roundtable, 2006-0197161C6 F - Étendu de l'allégement - Bulletin IT-470R |
Income Tax Act - Section 3 - Paragraph 3(a) |
potential exemption of commissions earned on life insurance policies issued to family members |
| 4 December 2006 Internal T.I. 2006-0211061I7 F - Rentes pour incapacité et stabilisation sociale |
Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(v) |
monthly disability benefits after accident, and monthly top-up payment after return to work at lower pay, came within ss. 56(1)(v) and 110(1)(f)(ii) |
| 2006-12-15 |
6 October 2006 Roundtable, 2006-0197041C6 F - Rente prescrite et hypothèque mobilière |
Income Tax Regulations - Regulation 304 - Subsection 304(1) - Paragraph 304(1)(c) - Subparagraph 304(1)(c)(iv) - Clause 304(1)(c)(iv)(D) |
prescribed annuity contract can be encumbered by a moveable hypothec |
| 6 October 2006 Roundtable, 2006-0197051C6 F - Abri fiscal: Don de valeurs mobilières |
Income Tax Act - Section 237.1 - Subsection 237.1(1) - Tax Shelter |
question of fact whether gift of securities described in s. 38(a.1) |
| 6 October 2006 Roundtable, 2006-0197211C6 F - Transfert de police d'ass-vie entre sociétés |
Income Tax Act - Section 15 - Subsection 15(1) |
s. 15(1) could apply to the individual shareholder of Aco and Bco where Aco transfers an insurance policy at an undervalue to Bco |
| Income Tax Act - Section 148 - Subsection 148(7) |
s. 148(7) applicable to policy transfer between sister corps |
| 2006-12-08 |
30 November 2006 External T.I. 2006-0191541E5 F - Primes d'assurance-vie et d'assurance-invalidité |
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures |
premiums on disability policy required by lender are capital expenditures |
| Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) |
guarantee fee does not include premiums on lender-required insurance policy |
| Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (j) |
tax free receipt of life insurance proceeds by lender on policy required by it of the borrower |
| Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (h) |
tax free receipt of disability insurance proceeds by lender on policy required by it of the borrower |
| Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.2) |
premiums on life insurance policy required by lender deductible even though loan government-guaranteed, but premiums on lender-required disability policy not deductible |
| 6 October 2006 Roundtable, 2006-0197151C6 F - Acquisition selon convention entre actionnaires |
Income Tax Act - Section 70 - Subsection 70(9.2) |
children’s exercise of a right in a shareholders’ agreement to acquire farmco shares that is triggered on their father’s death would not be a consequence of his death |
| Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(a) |
children exercising right in shareholders’ agreement to acquire shares on father's death would not be a consequence of his death, cf. if pursuant to his will |
| 15 November 2006 External T.I. 2006-0190041E5 F - Biogas / Codigestion Process / Produced for Sale |
Income Tax Regulations - Schedules - Schedule II - Class 43.1 |
supplementation of manure with organic waste in input to anaerobic digester would disqualify it as Class 43.1 property, as would the sale of more than 50% of the biogas produced |
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