| 2022-02-09 |
2021 Ruling 2021-0894621R3 F - Paiement à un membre qui quitte |
Income Tax Act - Section 3 - Paragraph 3(a) |
lump-sum assistance paid to a member of a religious community, who had taken vows of poverty, on his return to secular life, is not income |
| 2005-07-08 |
21 June 2005 Internal T.I. 2005-0123551I7 F - Montant forfaitaire de pension alimentaire |
Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount |
support amounts included annual top-up amounts |
| 2005-06-17 |
7 June 2005 External T.I. 2005-0121921E5 F - Paiement à un emphytéote |
Income Tax Act - Section 9 - Timing |
notwithstanding Canderel, tenant inducement payment must be amortized under matching principle if incurred for specific purposes of producing identifiable future revenue |
| Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense |
Belgega -finding that inducement paid to prospective emphyteuta (tenant) was capital expenditure - noted |
| 9 June 2005 Internal T.I. 2005-0122511I7 F - Créance irrécouvrable dans une OSBL |
Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) - Subparagraph 39(1)(c)(iv) |
loss on interest-bearing loan made by a director to an NPO qualified as BIL if NPO qualified as SBC |
| Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) |
a debt obligation bearing a reasonable rate of interest satisfies s. 40(2)(g)(ii) |
| 9 June 2005 External T.I. 2004-0097451E5 F - Régimes d'assurances collectives |
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) |
employees can potentially pay top-up amounts for further benefits or receive taxable compensation for opting for lower benefits |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) |
CRA criteria for determining whether there are 2 separate plans (one of which is fully employee-funded) |
| 6 June 2005 External T.I. 2005-0114481E5 F - Division 149(1)o.2)(ii)(C) |
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)(B) |
deferred proceeds receivable for real estate sale do not qualify as real property |
| 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)(C) |
loan that funded rental property acquisition may still qualify after partial sale of portfolio/replacement borrowing can also qualify |
| Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) |
loan that funded rental property acquisition may still qualify as “solely for the purpose of earning income” per s. 149(1)(o.2)(ii)(C) after partial sale of portfolio |
| 9 June 2005 Internal T.I. 2005-0115481I7 F - Avantages imposables/voyages |
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) |
since the particular shareholder-employees who benefited from trips provided by their employer’s supplier were known, the supplier should issue T4As to them |
| Income Tax Regulations - Regulation 200 - Subsection 200(2) - Paragraph 200(2)(g) |
T4As required to be issued to shareholder-employees of customers who were identifiable as receiving free trips – but not for sole proprietor customers |
| 9 June 2005 Internal T.I. 2005-0117851I7 F - Choix du paragraphe 14(1.01) de la Loi |
Income Tax Act - Section 14 - Subsection 14(1.01) |
taxpayer could not make s. 14(1.01) election where "exempt gains balance" in respect of his business for the year is not nil |
| 7 June 2005 External T.I. 2005-0121551E5 F - Déduction des intérêts - co-emprunteurs |
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) |
interest on money borrowed from spouse under line of credit for income-producing purpose is deductible |
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