Income Tax Severed Letters - 2015-10-21

Technical Interpretation - External

31 August 2015 External T.I. 2015-0582411E5 - Standby charge - employee required to use vehicle

CRA Tags
6(2), 6(1)(k), 6(1)(e)

Principal Issues: Is a standby charge benefit included in income when an employee is required to use, at all times, an employer's automobile which is emblazoned with the employer's logo, colours and advertising?

Position: Likely yes

Reasons: See response

Technical Interpretation - Internal

16 July 2015 Internal T.I. 2015-0590681I7 - Application of paragraph 162(10.1)(e) penalty

CRA Tags
233.3, 162(10.1)(e)
same date must be used for picking maximum amount

Principal Issues: How should the total amount subject to penalty be calculated?

Position: It should be the greatest of the total cost amounts of all specified foreign properties per period.

Reasons: Wording of s. 162(10.1)(e)