| 2006-11-17 |
7 October 2005 Roundtable, 2005-0141151C6 F - Lotissement de biens |
Income Tax Act - Section 248 - Subsection 248(21) |
s. 248(21) can apply to partitioning a building into separately-owned units |
| 12 September 2006 Internal T.I. 2005-0147801I7 F - Déduction pour frais judiciaires d'un employé |
Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(b) |
legal fees incurred in defending against allegations of harassment were non-deductible |
| 24 October 2006 Internal T.I. 2006-0203901I7 F - Avantage automobile |
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) |
bus stop near the employee’s home does not qualify as a pick-up point regarding the exception for employer-assisted commuting |
| 2006-11-10 |
26 October 2006 External T.I. 2006-0170341E5 F - Subsections 87(2.1) and 87(2.11) |
Income Tax Act - Section 87 - Subsection 87(2.1) |
s. 87(2.11) does not affect the aging of previously-incurred losses and is relevant to carry-backs by the Amalco |
| Income Tax Act - Section 87 - Subsection 87(2.11) |
purposes of s. 87(2.11) is to allow parent to use losses realized by the new corporation (so as to carry back) |
| 27 October 2006 External T.I. 2005-0157321E5 F - Winding-up of a wholly-owned corporation |
Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c) - Subparagraph 88(1)(c)(ii) |
character of property usually regarded as retained in the hands of the parent |
| Income Tax Act - Section 9 - Capital Gain vs. Profit - Goodwill |
character of property usually regarded as retained in the hands of the parent |
| 2006-11-03 |
19 October 2006 Internal T.I. 2006-0173261I7 F - Avantage conféré par une fiducie |
Income Tax Act - 101-110 - Section 105 - Subsection 105(2) |
no s. 105(2) benefit if no trust income, and benefit to beneficiary would generate a s. 104(6) deduction |
| Income Tax Act - Section 54 - Principal Residence - Paragraph (c.1) - Subparagraph (c.1)(iii) |
corporation as contingent beneficiary of cottage trust precludes use of principal residence exemption |
| Income Tax Act - 101-110 - Section 105 - Subsection 105(1) |
tolerance re use of trust personal use property by beneficiary or related person does not extend to unrelated person, but no benefit re payment of interest expense |
| Income Tax Act - Section 15 - Subsection 15(1) |
no s. 15(1) benefit if trust confers benefit directly on shareholder of a corporate beneficiary |
| 24 October 2006 External T.I. 2006-0174091E5 F - Disposition de parts d'un fonds réservé |
Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) - Subparagraph 39(1)(a)(iii) |
exchange of segregated fund units with redemption charges for other units without, is a disposition |
| Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (a) |
unit for unit exchange in segregated fund was disposition |
| 30 October 2006 Internal T.I. 2006-0199721I7 F - Escompte sur vente de compte clients |
Income Tax Act - Section 9 - Capital Gain vs. Profit - Loans/receivables |
the sale of receivables that were generated on income account is on income account |
| 2006-10-27 |
3 October 2006 External T.I. 2006-0204181E5 F - Déduction de frais de thérapie |
Income Tax Act - Section 118.4 - Subsection 118.4(1) - Paragraph 118.4(1)(c) |
scope of activities of daily living |
| 2006-10-20 |
28 September 2006 External T.I. 2006-0197841E5 F - Shareholders agreement & 256(1.4) |
Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(i) |
technically a contingent right to acquire control where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares |
| Income Tax Act - Section 256 - Subsection 256(1.4) - Paragraph 256(1.4)(a) |
s. 256(1.4) technically applies where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares |
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