| 2006-02-10 |
2 February 2006 Internal T.I. 2005-0129131I7 F - Assessing 163(2) penalty |
Income Tax Act - Section 163 - Subsection 163(2) |
s. 163(2) can be imposed where false adjustments are requested, without the necessity to first process those adjustments |
| 2006-02-03 |
31 January 2006 External T.I. 2005-0151041E5 F - Régimes de sécurité sociale étrangers |
Treaties - Income Tax Conventions - Article 29 |
plan recognized as a pension plan under Art. 29(5) of the Cda-France Convention cannot be an EBP |
| 27 January 2006 External T.I. 2005-0164611E5 F - Société immobilière de pension - sens de location |
Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(o.2) - Subparagraph 149(1)(o.2)(ii) - Clause 149(1)(o.2)(ii)(A) |
providing meals, medical services and housekeeping in a seniors apartment would put the corp. offside |
| 31 January 2006 External T.I. 2006-0167501E5 F - Retenues à la source |
Income Tax Regulations - Regulation 100 - Subsection 100(3) - Paragraph 100(3)(c) |
reasonable belief can be based on confirmation from annuitant |
| 2006-01-27 |
4 January 2006 Internal T.I. 2005-0115801I7 F - Convention de retraite |
Income Tax Act - Section 67 |
Petro-Canada applied re determining reasonableness |
| Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement |
contributions to a purported RCA that contemplated excessive benefits also were not in relation to an SDA because the contributions were instead were indirect shareholder appropriations |
| Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement |
arrangement was not an RCA because the benefits were not reasonable |
| Income Tax Act - Section 56 - Subsection 56(2) |
contributions to purported RCA that provided excessive benefits to employee/ultimate shareholders were included in the direct shareholders’ income under s. 56(2) |
| Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(r) |
excessive benefits would have resulted in denial under ss. 18(1)(o.2) and 20(1)(r) had the arrangement qualified as an RCA |
| 19 January 2006 External T.I. 2006-0165471E5 F - Fiducie exemptée d'impôt |
Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(z.1) |
exemption of trust for closure costs of Quebec disposal facility |
| 2006-01-20 |
21 December 2005 External T.I. 2005-0150711E5 F - Wind turbines - Class 43.1 |
Income Tax Regulations - Schedules - Schedule II - Class 43.1 - Paragraph (d) - Subparagraph (d)(v) |
lessor of lands can renounce rights of accession so that operator can own the wind turbines |
| 2006-01-13 |
6 January 2006 External T.I. 2005-0159421E5 F - Dons visant un programme particulier |
Income Tax Act - Section 248 - Subsection 248(30) |
acceptable to direct that donation to school where donor’s grandson is student can direct that the funds be used to purchase texts |
| 2006-01-06 |
22 December 2005 External T.I. 2005-0151091E5 F - Allocation de retraite - retenue à la source |
Income Tax Regulations - Regulation 100 - Subsection 100(3) - Paragraph 100(3)(c) |
confirmation of RRSP deduction limit is not required from the employee for the portion of the retiring allowance that is eligible for deduction under paragraph 60(j.1) |
| 22 December 2005 External T.I. 2005-0162001E5 F - Déductibilité police d'assurance-vie |
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.2) |
no assignment as required for premium deductibility by the taxpayer where the bank starts out as the policy owner |
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