2 August 2016 External T.I. 2014-0544941E5 F - Interaction between ss. 111(12) and 80.01(3) -- translation

Friday, November 18, 2016 - 18:50 | Author: carolannearmstrong

Principal Issues: In a particular situation, Aco holds all of the issued and outstanding shares of the capital stock of Bco. Both corporations are...

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24 June 2016 External T.I. 2015-0571471E5 F - Passe de ski familiale -- translation

Thursday, November 17, 2016 - 18:00 | Author: carolannearmstrong

Principal Issues: 1) Whether a family season ski and snowboard pass offered by an employer to his/her employees is a taxable benefit in a given...

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22 June 2016 Internal T.I. 2016-0632821I7 F - 93(2.01) & Capital Contribution -- translation

Thursday, October 20, 2016 - 15:43 | Author: carolannearmstrong

Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to...

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15 December 2014 Internal T.I. 2012-0445361I7 F - Remboursement de frais de déménagement -- translation

Tuesday, October 18, 2016 - 16:18 | Author: carolannearmstrong

Principle Issues: Is the reimbursement by an employer of certain moving expenses incurred by an employee a taxable benefit under paragraph 6(1)(a)...

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23 October 2015 External T.I. 2015-0614231E5 F - Frais de garde subventionnés -- translation

Tuesday, October 18, 2016 - 15:58 | Author: carolannearmstrong

Principal Issues: 1) Can the CRA confirm that the Additional Subsidized Childcare Contribution in Quebec is deductible in computing an...

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26 August 2015 External T.I. 2015-0564171E5 F - Paiements d'un RPAC à un Indien -- translation

Tuesday, October 18, 2016 - 12:50 | Author: carolannearmstrong

Principal Issues: 1) Should there be tax withholding on payments, that are not taxable per paragraph 81(1)(a), made to a participant of a PRPP who...

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6 August 2015 External T.I. 2015-0565651E5 F - Reliquat dévolu à une administration municipale -- translation

Friday, October 14, 2016 - 15:24 | Author: carolannearmstrong

Principal Issues: Would an entity, who is a non-profit organization per paragraph 149(1)(l), lose its tax-exempt status due to a clause in its...

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30 July 2015 External T.I. 2014-0552041E5 F - Permis XXXXXXXXXX -- translation

Friday, October 14, 2016 - 15:19 | Author: carolannearmstrong

Principal Issues: 1 - Is a XXXXXXXXXX license depreciable property to be included in class 14 or is it instead eligible capital property?; 2 - In...

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