Income Tax Severed Letters - 2022-08-31

Ruling

2021 Ruling 2021-0895631R3 - Post-mortem planning - Hybrid Pipeline

Unedited CRA Tags
84.1, 84(2), 245
2-year pipeline transactions
no stop-loss for s. 164(6) loss realized by estate before pipeline transactions

Principal Issues: Post-mortem planning.

Position: Favourable rulings provided.

Reasons: Previous positions and see below.

Technical Interpretation - External

13 January 2022 External T.I. 2021-0900691E5 - COVID-19 - Reasonable Standby Charge

Unedited CRA Tags
6(1)(e), 6(2), 6(2.3)
an employee cannot access the 2019 business use by a predecessor of a car to generate standby-charge relief under s. 6(2.3) in 2020/2021

Principal Issues: 1. Whether the reduced standby charge in subsection 6(2.3) of the Act can be utilized for an employee who receives access to an employer-provided automobile on January 1, 2020? 2. Whether a previous employee’s business usage from 2019 can be used to calculate the current employee’s reduced standby charge for 2020 in subsection 6(2.3) of the Act?

Position: 1. No. 2. No.

Reasons: 1. Subsection 6(2.3) of the Act is only applicable for an employee with an automobile provided by the same employer as in 2019. 2. Wording of subsection 6(2.3) of the Act.