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S3-F10-C2- Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subsection 207.06(2) Summary Under Tax Topics- Income Tax Act- Section 207.06- Subsection 207.06(2) Factors relevant to waiver of tax 2.36 Subsection 207.06(2) gives the Minister the authority to waive or cancel all or part of the 50% tax on prohibited investments or the 100% advantage tax in appropriate circumstances. ...

S3-F4-C1- General Discussion of Capital Cost Allowance-- summary under Paragraph 13(21.1)(b) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21.1)- Paragraph 13(21.1)(b) Example of reduction of terminal loss 1.94 … Example 9 In 2014, a taxpayer sells a building that is a rental property for $100,000. ... Building Fair market value (FMV) $100,000 Capital cost $200,000 Cost amount (UCC) $180,000 Land FMV $400,000 ACB $300,000 Results: The deemed proceeds of disposition of the building are calculated under paragraph 13(21.1)(b) as the total of A + B, where: A = the proceeds of disposition (POD) otherwise determined ($100,000) A = $100,000 and B = ½ of the amount by which the greater of: Cost amount (UCC) ($180,000); and FMV of building ($100,000) exceeds The POD otherwise determined (A) ($100,000) B = ½ of (180,000 – 100,000) B = $40,000 The deemed proceeds of disposition of the building are A ($100,000) + B ($40,000) = $140,000, resulting in a reduced terminal loss of $40,000 ($180,000- $140,000). ...

X nor his current or former spouse or common-law partner, or child had ordinarily inhabited the residence (see the rule discussed in ¶ 2.10- 2.12) until it was distributed by the trust to Mr. ... In other words, he would have been able to use the formula in ¶2.17- 2.26 to eliminate only the following portion of his $50,000 gain otherwise determined: Applying the formula A × (B ÷ C): A is $50,000 B is 1 + 3 (being tax years 2009 to 2011) C is 5 (being tax years 2007 to 2011) = $50,000 x (4 ÷ 5) = 40,000 ...

Component 1 = NIL (because Component 1 cannot be a negative amount)... Component 3 = $25,000... Component 4 = $40,000... Component 1 + Component 3 + Component 4 = $65,000 In the first tax year after amalgamation, Amalco realizes a capital gain of $90,000, the non-taxable portion of which is $45,000.... $25,000 of the non-taxable portion of the capital gain must first be applied to extinguish the notional negative balance of the capital gain component of the CDA of Amalco (Component 1 of the CDA) before the remaining $20,000 can be applied to increase the CDA balance of Amalco.... ...

S5-F2-C1- Foreign Tax Credit-- summary under Subsection 126(2) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(2) In determining the place where a business (or part of a business) is carried on (and, thus, the source of related business income for foreign tax credit purposes), the CRA generally considers that the situs of the profit-generating activities is as follows (para. 1.53): real estate development and sales – situs of properties merchandise trading – generally place of habitual sales completion securities trading – where trading decisions are made money lending – place of loan arrangement rentals – property location services – place of performance ...

Where an employer requires an employee to proceed directly from home to a point of call (for example, a client’s office), return home from a point of call, or travel between two regular places of employment, such travel is employment travel. … 2.21 … An employee may have more than one regular place of employment if the employee regularly performs their employment duties at more than one work location. 2.22.... Example 3 – Travel from home office...The employee regularly works from home, but attends bi-weekly meetings at the head office. ... Example 9 – Supplier award An employee is awarded a Caribbean cruise by her employer’s third-party supplier.... ...

Ownership requirement 1.21 CCA may be claimed only for property: owned by the taxpayer; deemed to be owned by the taxpayer; or in which the taxpayer has a leasehold interest. 1.22 … CCA may be claimed by the beneficial owner of a property if that person has all the incidents of title, such as possession, use and risk. … 1.23 … [W]here a taxpayer's asset is incorporated as an integral part into a property owned by another person. ... [W]here the building is used to earn income for only a short time prior to demolition, it is likely that the building will not be regarded as depreciable property unless the taxpayer can clearly establish that the prime intention on acquiring the building was for the purpose of gaining or producing income. … ...

Sources generally are determined as follows: interest/ dividends- the residence of the debtor/corporation (para. 1.58—1.59) real property rentals – property location (para. 1.60) rental of equipment etc. – country of use (para. 1.60) royalties – country where the related right is exploited (para. 1.61) capital gains from real estate – property location (para. 1.62) capital gains from stocks/bonds – location of exchange (para. 1.65) capital gains from other property – place of disposition/title transfer (para. 1.62) capital gains from deemed dispositions – Canada (para. 1.63) In the situation where the total allowable capital losses for all countries (including Canada) exceeds the amount of such losses that is deductible in computing the taxpayer's income under section 3, the taxpayer may allocate the losses amongst the countries in any manner provided that the amount of allowable capital losses allocated to any particular foreign country does not exceed the allowable capital losses actually incurred in that country; and the aggregate of the Canadian portion (if any) of the allowable capital losses and the various amounts allocated to the foreign countries is equal to the total amount of allowable capital losses that is deductible in calculating the taxpayer's income under section 3 of the Act (para. 1.92, including numerical example). " Any tax in the nature of an income, gains, or profits tax that is paid for the year to a foreign jurisdiction in respect of a capital gain should be included in the non-business-income tax paid to that jurisdiction. ...

However, provided the conditions in ¶ 4.3 (or ¶ 4.4) and ¶ 4.13 are met, the CRA generally allows an individual to deduct moving expenses paid by the individual’s spouse or common-law partner. ...

S4-F14-C1- Artists and Writers-- summary under Paragraph 8(1)(q) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(q) Example 5 (showing that an employed musician may be better off deducting his expenses of travelling to performances under s. 8(1)(h) rather than (q)) 1.61 … Claude is a musician who earned employment income of $22,500 during the tax year as a performer of musical works. ... (i) Calculation of Claude’s 8(1)(q) annual limit for artists’ employment expenses under Scenario B Lesser of A or B: A = 1,000, and B = 4,500 (20% of $22,500); $1,000 Minus C: amounts deducted in the year under paragraphs 8(1)(j) or (p) $350 Claude’s annual 8(1)(q) limit $650 (ii) Calculation of total allowable expenses under Scenario B Advertising and travel expenses deductible under paragraph 8(1)(q) (the eligible expenses paid are $2,000 ($700 + $1,300), but the deduction cannot exceed the limit of $650) $650 Add: CCA deductible under paragraph 8(1)(p) $350 Total amount deductible in the current year $1,000 The amount of Claude’s eligible artists’ employment expenses under paragraph 8(1)(q) in Scenario B is $2,000 instead of $700 as in Scenario A. ... As a result, the amount of artists' employment expenses that can be carried forward to deduct in a future year is still $50 ($2,000 eligible – $650 deductible under paragraph 8(1)(q) – $1,300 deductible under paragraph 8(1)(h)). ...