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CRA stated: [T]he benefit arising from the person's use of the aircraft by the corporation's founder-president should be based on the price of a regular first class ticket for a scheduled flight to the same destination, as the founder-president received the benefit as an employee of the corporation. (2) When an aircraft is owned or leased primarily for business purposes and it makes a flight the main purpose of which is to provide free or subsidized transportation for the personal benefit of one or more employees or shareholders, the value of the resulting benefit is included in computing the income of the employee or shareholder. ...

Under ITR paragraph 103(6)(a), a payment described in subparagraph 40(1)(a)(i) or (iii) or paragraph 40(1)(c) of the Income Tax Application Rules (footnote 2) constitutes a "lump sum payment" for the purposes of ITR subsection 103(4). ...

It would appear that there is no requirement for the issuer to report the deemed interest under Reg. 201(1), and conversely there would be a requirement to so report the full amount of the first interest coupon that was paid, even though the taxpayer had already been required to recognize a portion of such interest under s. 12(9) and Regs. 7000(1) and (2). ...

Paragraphs 2 and 3 of IT-357R2 provide some examples of training expenses that are considered to be a capital expenditure. ...

In Scenario 2, 40% of the lots were non-commercial woodlots that were not used in the farming business carried on by Mrs. ...

15 November 2016 Internal T.I. 2015-0577201I7 F- Employés du transport-- summary under Subparagraph 6(1)(b)(vii) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii) per kilometer “accommodation” allowances paid to long-haul drivers not in excess of their vouchered restaurant expenses were likely unreasonable A trucking company pays its employed long-haul drivers allowances for accommodation expenses of $0.04 per kilometer (scenarios 1 and 3) or of $75 per day spent away (scenario 2). ...

XXIV, para. 2 of the Canada-U.S. Treaty be relied upon to claim a foreign tax credit taxes paid to the U.S. on for the member’s share of of the LLC’s income for the year when there is a distribution in respect of that income from the LLC regardless of whether the distribution takes place in the same taxation year when the income was earned by the LLC? ...

In the 2 nd situation, K owns 65% of BuyCo, K’s brother owns 100% of SellCo A and K’s son owns 100% of SellCo B. ...

For example, Section 3 of Part 2 of the supplement, and Sections 1-4 of Part 3 of the supplement, specifically refer to taxation years of the affiliate ending before the entity’s taxation year, whereas here the amalgamation would not cause a year-end for the foreign affiliates. ...

CRA stated: in general, a biomass heating system acquired by a Taxpayer could be included in Class 43.2 of Schedule II if the following conditions are satisfied: 1) The biomass heating system is fuelled only by an "eligible waste fuel" (such as wood pellets), a "fossil fuel" or a combination of those. 2) The heating system is used by the Taxpayer primarily to produce thermal energy through the consumption of an "eligible waste fuel" i.e., for example, wood pellets must be the main fuel producing the thermal energy used for eligible purposes. 3) The thermal energy produced by such biomass heating system must be used directly in an industrial process or a greenhouse, operated either by the Taxpayer or by the Taxpayer's customers. 4) The biomass heating system must be located in Canada. 5) The Taxpayer acquired the biomass heating system for use in the course of earning income from a business carried on in Canada or income from property situated in Canada. … [T]he NRCan Guide indicates that expenses for eligible property incorporated into a ground source heat pump system that qualifies for Class 43.2 treatment (by virtue of subparagraph (d)(i) of Class 43.1), include: The purchase and installation of heat pumps, pumps complete with controls and regulators. ...