Translations of recent severed letters

Bundle Date Translated severed letter Summaries under Summary descriptor
1999-12-10 8 November 1999 External T.I. 9905015 F - PLACEMENTS EN COMMUN - DÉCÈS D'UN DÉTENTEUR Income Tax Act - Section 20 - Subsection 20(14) application of s. 20(14) to a joint bank account of deceased and survivor
18 October 1999 Internal T.I. 9905377 F - ALLOCATION FRAIS DE DEPLACEMENT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) if per kilometre allowance is unreasonable, total allowance is included in income
15 November 1999 External T.I. 9907215 F - STAGES INTERNATIONAUX DE L'ACDI Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(iii) meaning of a special allowance
26 October 1999 Internal T.I. 9913080 F - EXPROPRIATION Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition - Paragraph (d) costs of moving equipment assimilated to proceeds in respect of expropriation of plant
4 June 1999 Internal T.I. 9913100 F - APPLICATION 40(2)G)(II), 20(1)C) ET 18(1)A) Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) s. 12 requires the recognition of income even where the associated expenses were not incurred for profit
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose s. 18(1)(a) can deny an expense not incurred in an activity with a reasonable expectation of profit even where s. 12 specifically requires inclusion of the smaller gross income
4 June 1999 Internal T.I. 9913120 F - APPLICATION DE 20(1)F) Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) redemption proceeds of stock option were deductible under s. 20(1)(f)
29 June 1999 Internal T.I. 9913180 F - AFFACTURAGE Income Tax Act - Section 9 - Capital Gain vs. Profit - Debt/ receivables sale of trade receivables to securitization vehicle generally on income account
16 September 1999 Income Tax Severed Letter 9913210 F - SYNDICAT DE COPROPRIÉTAIRES Income Tax Act - Section 248 - Subsection 248(1) - Corporation syndicate of co-owners is a corporation
Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) potential for distribution of income on its liquidation would not cause a syndicate of co-owners to not qualify as an NPO
24 June 1999 Internal T.I. 9913420 F - BFT- HONORAIRE DE GESTION Income Tax Regulations - Regulation 5202 - Cost of Labour cost of labour included only the salary component of managementco fees
24 June 1999 Internal T.I. 9913480 F - BIA REGROUPEMENT D'ENTREPRISE Income Tax Regulations - Schedules - Schedule II - Class 14.1 fees incurred in acquiring a similar business may be eligible capital expenditures
27 July 1999 Internal T.I. 9913490 F - LOCATION- MONTANT REÇU- JUGEMENT Income Tax Act - Section 9 - Compensation Payments amount received for a release could constitute proceeds of disposition of a right
27 September 1999 Internal T.I. 9916367 F - REMISE DE DETTE/PRET ETUDIANT Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) partial loan repayments where students achieved their degrees were prizes for achievement
Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount partial repayment of loans under a Quebec government program did not represent loan forgiveness (the lenders themselves did not forgive the loans)
29 June 1999 APFF Roundtable Q. 12, 9913090 F - DÉDUCTIBILITÉ DES INTÉRÊTS Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest non-deductible where there is no expectation of profit from the investment
8 June 1999 APFF Roundtable Q. 51, 9913160 F - PAIEMENT INCITATIF À LA LOCATION Income Tax Act - Section 9 - Timing Canderel indicates that the onus is on CCRA to demonstrate that its income computation method provides a more accurate picture/ those in identical fact situations to Canderel can currently deduct their unamortized TIP balance

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