Principal Issues: Is foreign online advertising deductible?
Position: Generally, foreign online advertising is deductible.
Principales Questions: Under the presented scenario, whether a deemed gain under subsection 40(3.1) realized by a partnership can be included in the CDA of its corporate limited partner.
Position Adoptée: No.
Raisons: Our position is that generally the partnership's income retains its characteristics as to source and nature when allocated to the partners.
Principal Issues: Will subsection 80(15) apply in a tiered partnership structure?
Reasons: Since section 80 must be applied to determine net income of a partnership, subsections 96(1) and 102(2) would apply to treat the partnerships as separate persons for purposes of section 80.
Principal Issues: Is an employer reimbursement for tax-advisory-services expenses incurred due to employer payroll errors included in the employee's income?
Reasons: See response