Income Tax Severed Letters - 2017-08-16

Technical Interpretation - External

13 July 2017 External T.I. 2017-0702001E5 - Principal residence, land

Unedited CRA Tags
54

Principal Issues: A fire destroys a principal residence and insurance proceeds are received. If the land is sold in a subsequent year, can any of the gain be sheltered by the principal residence exemption?

Position: Possibly.

Reasons: See below.

11 July 2017 External T.I. 2017-0693761E5 - Commission income - corporation

Unedited CRA Tags
9(1)

Principal Issues: Whether an individual can earn commission income through a corporation.

Position: Question of fact. Possibly yes.

Reasons: See below.

26 June 2017 External T.I. 2017-0704801E5 - Social Assistance - Ontario Basic Income Pilot

Unedited CRA Tags
56(1)(u); 110(1)(f); Reg 233(2)

Principal Issues: Whether payments made under the Ontario Basic Income Pilot program are considered social assistance?

Position: Most likely yes.

Reasons: They are based on an income test.