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21 February 2024 External T.I. 2022-0951441E5- Replacement Property – Undivided Interest Unedited CRA Tags 13(4), 13(4.1), 44(1), 44(5), 54 "capital property", 248(1) “Property" Principal Issues: Where a taxpayer acquires an undivided interest in a particular property, whether the particular property can qualify as a "replacement property”, as defined by subsections 13(4.1) and 44(5) of the Act? ... XXXXXXXXXX 2022-095144 Troy Neave February 21, 2024 Dear XXXXXXXXXX: Re: Replacement Property – Undivided Interest We are writing in response to your letter dated September 3, 2022, wherein you requested our views on whether, for purposes of the replacement property rules in subsections 13(4) and 44(1) of the Income Tax Act (the “Act”), a particular property could be considered a replacement property if the nature of ownership is an undivided interest. ...

27 August 2012 External T.I. 2012-0438001E5- Taxable Benefits – Employer-Provided Vehicles Unedited CRA Tags 6(1)(a); 6(1)(e); 6(1)(k); 6(6) Principal Issues: 1. ... Baltkois August 27, 2012 Dear XXXXXXXXXX: Re: Taxable Benefits – Employer-Provided Vehicles We are writing in response to your email dated February 22, 2012, in which you asked whether an employee’s use of an employer-provided motor vehicle would give rise to a taxable benefit under the Income Tax Act (the “Act”) for various scenarios. ... Additional information on this subject is available in Interpretation Bulletin IT-63R5, Benefits, Including Standby Charge for an Automobile, from the Personal Use of a Motor Vehicle Supplied by an Employer- After 1992, Form RC18 – Calculating Automobile Benefits for 2011, and through the Automobile Benefits Online Calculator which is available on the CRA website. ...

19 February 2014 External T.I. 2013-0484761E5- Taxable Benefits – Employer-Provided Vehicles CRA Tags 6(1)(a) 6(1)(k) 6(1)(e) Principal Issues: Whether a taxable benefit would arise in connection with an employee's use of an employer-provided vehicle? ... Baltkois February 19, 2014 Dear XXXXXXXXXX: Re: Taxable Benefits – Employer-Provided Vehicles We are writing in response to your letter dated March 21, 2013, in which you asked whether an employee's use of an employer-provided vehicle would give rise to a taxable benefit under the Income Tax Act (the Act). ...

2 August 2001 External T.I. 2001-0085835- PUSH DOWN ACCOUNTING & LCT Unedited CRA Tags 181(3) 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. ... XXXXXXXXXX 2001-008583 August 2, 2001 Dear XXXXXXXXXX: Re: Push Down Accounting & Part I.3 Tax This is in your reply to your inquiry on the above noted subject addressed to the Sudbury Taxation Services Office, regarding a technical interpretation of the CCRA's position as described in paragraph 15 of IT-532. ...

13 December 2001 External T.I. 2001-0019525- Relationship between a trust & corporation Unedited CRA Tags 251(2) 256(7) 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. ... Fawcett & Son, Limited v. The Queen, 80 DTC 6195, no difference should be drawn between Mr. ...

28 February 2003 External T.I. 2002-0180945- HONORARIA & TRAVEL EXPENSE Unedited CRA Tags 6(1)(c) 6(1)(b)(vii.1) 81(3) 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. ... XXXXXXXXXX 613-957-8973 2002-018094 February 28, 2003 Dear XXXXXXXXXX: Re: Honoraria & Reimbursement of Travel Expenses We are writing in response to your letter of December 19, 2002, regarding a technical interpretation request on the above-noted issue, as it pertains to XXXXXXXXXX (the Committee). ...

19 February 2019 External T.I. 2018-0781651E5- Indian Employment Income – Guideline 4 Unedited CRA Tags 81(1)(a) Principal Issues: Whether employment income would be exempt from tax under Guideline 4 of the Indian Act Exemption for Employment Income Guidelines. ... XXXXXXXXXX 2018-078165 Michel Gauthier February 19, 2019 Dear XXXXXXXXXX: Re: Indian Employment Income – Guideline 4 This is in reply to your email dated October 10, 2018. ...

8 September 2021 External T.I. 2021-0879941E5- METC – Cost of a nebulizer Unedited CRA Tags ITA: subsections 118.2(2); 118.4(2); subparagraph 118.2(2)(m), and IT Regulation 5700. ... Underhill September 8, 2021 Dear XXXXXXXXXX: Re: Medical expenses – Nebulizer We are writing in response to your correspondence received on February 4, 2021, asking if the cost of a home nebulizer, including a replacement part such as a nebulizer cup, is an eligible medical expense for the purposes of the medical expense tax credit (METC). ...

28 January 2022 External T.I. 2020-0860211E5- Principal Residence Exemption – Unedited CRA Tags Paragraph 54(e)- definition of principal residence and land in excess of one-half hectare; 40(2)(b) Principal Issues: Whether the taxpayers are eligible to claim the principal residence exemption on the portion of their land in excess of one-half hectare. ... Foggia, CPA, CA January 28, 2022 Dear XXXXXXXXXX: Re: Principal Residence Exemption – Excess Land This is in response to your correspondence of August 4, 2020 and a subsequent telephone conversation (Couvrette/XXXXXXXXXX) of August 25, 2020, wherein you requested our views concerning the disposition of a residence where the total area of the land upon which the housing unit is situated exceeds one-half hectare. ...

5 December 2022 External T.I. 2021-0915921E5- ELHT – Class of beneficiaries Unedited CRA Tags 144.1(2)(e) and (f) Principal Issues: Whether a group comprised of employees from multiple participating employers who are entitled to different benefit entitlements may constitute a class of beneficiaries for purposes of subparagraph 144.1(2)(e)(i) of the Act. ... Zabolotney December 5, 2022 Dear XXXXXXXXXX: Re: Employee Life and Health Trusts – Class of beneficiaries We are writing in reply to your correspondence of November 3, 2021, wherein you asked for our comments regarding the beneficiary class rules in paragraph 144.1(2)(e) of the Income Tax Act (the ”Act”). ...