| 2006-04-07 |
28 March 2006 Internal T.I. 2005-0109761I7 F - Commandite reçue par une athlète |
Income Tax Act - Section 3 - Paragraph 3(a) |
sponsorship received by amateur student athlete was not from a source of income |
| 16 March 2006 External T.I. 2005-0133301E5 F - Arrérages pension alimentaire reçus par succession |
Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(b) |
support arrears received by estate were tax-free |
| Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees |
legal fees to settle an estate are non-deductible |
| 28 March 2006 Internal T.I. 2005-0151711I7 F - Récompense visée par règlement |
Income Tax Regulations - Regulation 7700 |
prize to award excellence in teaching materials was a prescribed prize |
| 29 March 2006 Internal T.I. 2006-0171171I7 F - Convention de retraite |
Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement |
plan was not an RCA because benefits were unreasonable |
| Income Tax Act - Section 67 |
application of a version of the Gabco test |
| 2006-03-31 |
6 March 2006 External T.I. 2005-0155271E5 F - Disposition d'une participation au capital |
Income Tax Act - 101-110 - Section 107 - Subsection 107(2) - Paragraph 107(2)(a) |
computation of capital gain, where another taxpayer paid by another beneficiary to surrender his or her capital interest in the estate, based on para. (b) of “cost amount” |
| 2006-03-24 |
22 March 2006 External T.I. 2005-0133061E5 F - Limitation Period Collection of Debts |
Income Tax Act - Section 222 - Subsection 222(4) - Paragraph 222(4)(a) - Subparagraph 222(4)(a)(ii) |
10-year limitation period did not start running for a pre-2004 debt until March 4, 2004 |
| 21 March 2006 External T.I. 2005-0158451E5 F - Québec Mining Duties Act - Credit for Losses |
Income Tax Act - Section 66.1 - Subsection 66.1(6) - Cumulative Canadian exploration expense - Element J |
credit under the Quebec Mining Duties Act based on exploration and development losses of operator was not “assistance" under J |
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x.2) |
credit under the Quebec Mining Duties Act based on exploration and development losses of operator was not includible under s. 12(1)(x.2) |
| Income Tax Act - Section 66 - Subsection 66(12.6) - Paragraph 66(12.6)(a) |
credit under the Quebec Mining Duties Act based on exploration and development losses of operator was too remote from the exploration to reduce the renounced CEE |
| 2006-03-17 |
14 March 2006 External T.I. 2006-0170971E5 F - CRCE/Test Wind Turbine-FEREEC/Éolienne d'essai |
Income Tax Regulations - Regulation 1219 - Subsection 1219(3) - Paragraph 1219(3)(f) |
requirement for 1500 m spacing of wind turbines not satisfied |
| 15 March 2006 External T.I. 2005-0124911E5 F - Prestation compensatoire française |
Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount |
life annuity, but not lump sum, received from divorced ex-spouse in France as “compensatory allowances” under the French Civil Code was taxable as support |
| Treaties - Income Tax Conventions - Article 18 |
life annuity, was to be treated for Treaty purposes as alimony or similar payments since it was treated by CRA as a support amount under ITA |
| Treaties - Income Tax Conventions - Article 3 |
treatment of a life annuity under ITA, as a support amount meant that it was to be treated for Treaty purposes as alimony or similar payments |
| Treaties - Income Tax Conventions - Article 21 |
non-taxability of lump sum compensation allowance under French law not altered by Art. 21 |
| 16 March 2006 External T.I. 2006-0167361E5 F - Options et droits - Alinéa 251(5)b) |
Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) |
bankruptcy exception does not include mere insolvency/no application where corporation is required under USA to redeem shares or under a letter of intent |
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