| 2022-03-16 |
4 May 2021 External T.I. 2020-0853361E5 F - Frais d'asepsie / asepsis fees |
Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(a) |
additional dentists’ charges for COVID precautions qualified |
| 1 June 2021 Internal T.I. 2020-0858471I7 F - Paiement forfaitaire rétroactif admissible |
Income Tax Act - 101-110 - Section 110.2 - Subsection 110.2(1) - Qualifying Amount - Paragraph (a) - Subparagraph (a)(i) |
pay equity awards agreed to consensually did not qualify |
| 23 June 2020 External T.I. 2020-0847641E5 F - SSUC - Entité déterminée et institution publique |
|
CEWS comments mirror those in 2020-0846261E5 |
| 2005-04-15 |
1 April 2005 External T.I. 2004-0097171E5 F - Item gagné lors d'un tirage |
Income Tax Act - Section 3 - Paragraph 3(a) |
position on exempt lottery winnings did not apply to extent prize was indirectly funded by employer |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) |
prize won in raffle by employee was includible in employee’s income to the extent of the portion of its value that was funded by the employer rather than fellow employees |
| 31 March 2005 External T.I. 2004-0101171E5 F - Entreprise de placement déterminée |
Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business - Paragraph (b) |
para. (b) test can be satisfied if the affiliate provides sufficient part-time employees |
| 7 April 2005 External T.I. 2004-0103551E5 F - Choix - Engagement de non-concurrence |
Income Tax Act - Section 56.4 - Subsection 56.4(3) - Paragraph 56.4(3)(c) - Subparagraph 56.4(3)(c)(vi) |
election to be made on form of letter on CRA website |
| 7 April 2005 External T.I. 2004-0099191E5 F - Inventaire d'un artiste |
Income Tax Act - Section 10 - Subsection 10(6) |
reporting nil inventory on T2124 form is treated as making the election |
| Income Tax Act - Section 70 - Subsection 70(2) |
application of s. 70(2) or (3) to artist’s inventory |
| Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives |
legatee generally acquires a deceased artist’s inventory on capital account |
| 7 April 2005 Internal T.I. 2005-0110991I7 F - Frais de garde d'enfants |
Income Tax Act - Section 63 - Subsection 63(2) - Paragraph 63(2)(b) - Element C - Subparagraph (i) - Clause (i)(B) - Subclause (i)(B)(I) |
“period of not less than 2 weeks” refers to 2 consecutive weeks |
| 11 April 2005 External T.I. 2005-0112321E5 F - Price adjustment clause |
Income Tax Act - Section 51 - Subsection 51(2) |
CRA may accept a price adjustment clause adjusting of share consideration on s. 51 exchange if genuine attempt to establish FMV and issue of intervening share cancellation is addressed |
| General Concepts - Effective Date |
CRA may also accept a price adjustment clause for improving the attributes of the shares received on an exchange so as to equal the exchange price |
| Income Tax Act - Section 15 - Subsection 15(1) |
where FMV of pre shares received on estate-freeze s. 51 exchange was less than that of the exchanged common shares, CRA would apply s. 51(2), not s. 15(1) |
| 31 March 2005 External T.I. 2004-0093651E5 F - Primes d'assurance-vie et d'assurance-invalidité |
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.2) |
guarantee respecting another aspect of a loan by a government fund does not preclude deductibility of premiums on life policy assigned as security to bank |
| 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 |
| 4 April 2005 External T.I. 2004-0099411E5 F - Transfert de contrat de crédit-bail |
Income Tax Act - Section 68 |
purchase price for lease with bargain purchase option likely to be allocated to the embedded option |
| Income Tax Act - Section 49 - Subsection 49(1) |
CRA position on allocating lease payments to bargain purchase option extended to assignment of the lease agreement |
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