| 2016-11-30 |
7 October 2016 APFF Roundtable Q. 1A, 2016-0652951C6 F - Penalty late filed election-subsection 85(8) |
Income Tax Act - Section 85 - Subsection 85(8) |
penalty calculated on a global basis |
| 7 October 2016 APFF Roundtable Q. 1B, 2016-0652761C6 F - T4A filing |
Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(g) |
limited exceptions to T4A reporting |
| Income Tax Regulations - Regulation 200 - Subsection 200(2) |
no expanded relief from the broad T4A reporting requirements |
| 7 October 2016 APFF Roundtable Q. 1C, 2016-0652771C6 F - T106 and multiple year ends |
Income Tax Act - Section 231.1 - Subsection 233.1(2) |
acquisition of control generally will not generate additional T106 filings |
| 7 October 2016 APFF Roundtable Q. 2, 2016-0652841C6 F - Changement partiel d’usage - immeuble locatif et résidentiel |
Income Tax Act - Section 54 - Principal Residence |
triplex contained separate housing units |
| Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) |
on sale of triplex, individual can claim exemption only for years in which particular units were used personally or by children |
| Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) |
switch between which triplex units used for personal/family rental or 3rd-party rental did not trigger change of use |
| 7 October 2016 APFF Roundtable Q. 3, 2016-0652851C6 F - Annulation d'une promesse d'achat sur une maison |
Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(b) |
no capital loss for damages paid for breach of purchase obligation |
| Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) |
damages for breach of covenant to purchase principal residence not covered |
| 7 October 2016 APFF Roundtable Q. 4, 2016-0652801C6 F - Salary Deferral Arrangement |
Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements - Paragraph (k) |
no backdating as of the year end |
| 7 October 2016 APFF Roundtable Q. 5, 2016-0652861C6 F - Véhicules électriques - rabais |
Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A |
cost not reduced under general principles buy government assistance |
| Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(g) |
vehicle assistance paid indirectly (to dealer) covered |
| Income Tax Act - Section 6 - Subsection 6(2) |
Quebec government assistance does not reduce cost of purchased vehicle, but treated as compensation to dealer-lessor prorated over term of lease |
| Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A |
installation cost included |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e) |
use of manufacturer’s electricity-use standard |
| 7 October 2016 APFF Roundtable Q. 6, 2016-0652821C6 F - Graduated Rate Estate - Total Charitable Gifts |
Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts - Paragraph (c) - Subparagraph (c)(ii) |
right of GREs to carry forward donations for five years |
| 7 October 2016 APFF Roundtable Q. 7, 2016-0652971C6 F - Paragraph 251(5)(b) and subsection 256(1.4) |
Income Tax Act - Section 256 - Subsection 256(1.4) - Paragraph 256(1.4)(a) |
does not include right to find a 3rd party purchaser for another’s shares |
| Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(i) |
right to find 3rd party purchaser |
| Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(ii) |
may include right arising after triggering of event over which no control |
| 2016-11-23 |
12 December 2014 Internal T.I. 2014-0524751I7 F - Redevances perçues d'avance |
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) |
irrevocable royalty prepayment under s. 12(1)(a) or 9 |
| Income Tax Act - Section 9 - Timing |
lump sum irrevocable prepayment of contingent future royalties fully included |
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