Translations of recent severed letters

Bundle Date Translated severed letter Summaries under Summary descriptor
2000-10-27 19 October 2000 External T.I. 2000-0027795 F - SOCIETES PRIVEES SOUS CONTROLE CDN Income Tax Act - Section 181.5 - Subsection 181.5(6) corporations controlled by the provincial Crown would not be required to share their capital deduction
Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation corporations controlled by the provincial Crown treated as CCPCs
Income Tax Act - Section 248 - Subsection 248(1) - Person provincial Crown is a person
23 October 2000 External T.I. 2000-0038305 F - REMBOURSEMENT DE PRIME CONJOINT MEME SEXE Income Tax Act - Section 146 - Subsection 146(8.1) election to have the deceased by a common-law partner could be made with deceased’s executor, thereby enabling a s. 146(8.1) election
2000-10-13 2 October 2000 External T.I. 2000-0015825 F - ACTIFS AUX FINS DE LA LOI Income Tax Act - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (c) a future income tax asset (including one not recognized on the balance sheet) must be taken into account for QSBCS and SBC purposes, but is not used in the business
Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation a future income tax asset is an asset for QSBCS and SBC purposes, but is not used in the business
18 September 2000 External T.I. 2000-0026805 F - PAIEMENTS DANS LE CADRE D'UN CONGEDIEMENT Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance payment in lieu of reasonable notice was s. 5 employment income
Income Tax Regulations - Regulation 102 - Subsection 102(1) reimbursed legal costs of dismissed employee paid by the employer are not subject to withholding if such costs were deductible under s. 8(1)(b)
3 October 2000 Internal T.I. 2000-0039997 F - VENDEAU-CONFERENCE ET CONGRES Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) - Subparagraph 8(1)(f)(v) costs of presentations to improve skills of salespeople who generated commissions to the taxpayer were not capital expenditures, cf. cost of attending conference
20 September 2000 External T.I. 2000-0043435 F - Associé quittant société de personnes Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) adjustments to avoid double taxation on a completed withdrawal from a partnership are considered first by the TSO, generally as part of an audit
2000-09-29 14 September 2000 External T.I. 2000-0023515 F - TAXE DE VENTE AVANTAGE IMPOSABLE Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) payment by employer of sales tax on insurance premiums under an employee-funded sickness or accident insurance plan did not taint the plan
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) payment by employer of sales tax on insurance premiums under an employee-funded sickness or accident insurance plan is a taxable benefit
14 September 2000 External T.I. 2000-0037085 F - ALLOCATION DE RETRAITE Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) a lump sum paid in satisfaction of an insurer's obligations under a wage loss replacement plan were taxable irrespective of whether paid as a lump sum and via the employer
Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) lump sum wage loss payments paid by an insurance company to the employer for on-payment were subject to source deductions
Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance a lump sum amount paid in satisfaction of salary insurance benefits could not be transmuted into a retiring allowance
2000-09-15 11 September 2000 External T.I. 2000-0045115 F - FERR TRANSFERT Income Tax Act - Section 60 - Paragraph 60(l) an individual's spouse may make a transfer from a spousal RRIF a non-spousal RRIF of the spouse (which then becomes a spousal RRIF)
Income Tax Act - Section 146.3 - Subsection 146.3(5.1) spousal RRIF status has relevance only for purposes of s. 146.3(5.1)

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