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17 July 1995 External T.I. 9500075- VACATION BUYING & SELLING IN A FLEX PLAN Unedited CRA Tags 6(1)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: whether a flexible benefit plan which permits the purchase of vacation will be considered a salary deferral arrangement Position TAKEN: question of fact Reasons FOR POSITION TAKEN: if a plan permits the carryforward of purchased vacation, such a plan could be a SDA depending on whether the potential tax deferral associated with such a carryforward can be considered one of the main purposes of the arrangement & thus we will not rule or offer an opinion. ...

14 September 1995 External T.I. 9515775- FAMILY MORTGAGE PLAN ARRANGEMENT- 56(2) & 56(4) Unedited CRA Tags 56(2) 56(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Yours truly, Chief Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

22 November 1995 External T.I. 9518245- SCC EGAN & EFFECT ON SAME SEX PARTNERS HEALTH PLAN Unedited CRA Tags 6(1)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: details on how to segregate one plan so that the part that qualifies as phsp will not be considered an ebp & whether SCC decision in Egan v the Queen will impact on our position Position: separate plans require no cross-susidization-the SCC decision upholds the OAS extended def'n of spouse so there is no reason to believe that the ITA distinction would offend the Charter Reasons: see above A. ...

3 January 2002 External T.I. 2001-0067955- Application of 75(2) & 107(4.1) to a trust Unedited CRA Tags 75(2) 107(4.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Murphy Manager Trusts Section International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

16 May 2002 External T.I. 2002-0135765- E-Commerce & Computer Software Unedited CRA Tags 212(1)(d) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Position Paper Internet Commerce, which evolved from 2 sources:- a 1998 CCRA Technical Advisory Group (TAG) on Interpretation & International Cooperation; and- The "Taxation Framework Conditions", agreed upon in Ottawa in 1998 by member countries of the OECD. 2. ...

22 October 2002 External T.I. 2002-0161565- DIRECTOR & OTHER FEES Unedited CRA Tags 6(1)(c) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Subsection 5(1) of the Act states that "... a taxpayer's income for a taxation year from an office or employment is the salary, wages and other remuneration, including gratuities, received by the taxpayer in the year". ...

24 January 2003 External T.I. 2002-0180955- Active Solar System & Cogeneration Equip. ... With regard to the heat distribution system and the cost of buildings and structures that support and house the micro-turbine units, the postamble of paragraph (a) of Class 43.1 describes property that cannot be included in the class under that paragraph, namely: ".... buildings or other structures, heat rejection equipment (such as condensers and cooling water systems), transmission equipment, distribution equipment, fuel storage facilities and fuel handling equipment," Since distribution equipment is specifically excluded, in our view, none of the components of the heat distribution system is eligible for inclusion in Class 43.1. ...

25 October 2000 External T.I. 2000-0016025- HOME OFFICE & TRAVEL EXP. ... Paragraph 1 of IT-352R2 states that "... subparagraphs 8(1)(i)(ii) and (iii) allow a taxpayer, in computing income for a taxation year from an office or employment, to deduct amounts paid in the year as expenses for office rent, supplies and salary to an assistant or substitute. ...

14 December 2000 External T.I. 2000-0044105- SHAREHOLDER LOANS & REPAYMENTS Unedited CRA Tags 15(2) 15(2.6) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reasons: The exception will only apply if the loans and repayments are not part of " a series of loans or other transactions and repayments". ...

16 November 2020 External T.I. 2020-0864141E5- TI – Tax Treatment of Loan Forgiveness under CEBA Unedited CRA Tags 12(1)(x); 12(2.2); 80 * Principal Issues: What is the tax treatment of forgiveable portion of a loan granted under the CEBA program? ...