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Technical Interpretation - External summary
7 June 2016 External T.I. 2014-0532451E5 F - Crédit pour la création d’emplois pour apprentis -- summary under Eligible Apprentice
" … Furthermore, during the period of time a worker in the Quebec construction industry holds an exemption issued by the Commission…the individual is not an "eligible apprentice"…. ...
Technical Interpretation - External summary
23 January 2012 External T.I. 2011-0424671E5 F - Avantage imposable - Stationnement -- summary under Paragraph 6(1)(a)
CRA then stated: As an indication, where an employee is required to use the employee’s automobile, or a car provided by the employer, three or more days a week to perform the duties of employment, and uses the parking space for that purpose, we generally consider … that the parking space is used regularly for reasons related to the employee’s employment. ...
Technical Interpretation - External summary
15 August 2012 External T.I. 2012-0444461E5 F - Pompiers volontaires -- summary under Subsection 81(4)
. … [A]n individual who is required to work a minimum number of hours in a given period of time, except for a very limited number of hours, is generally not considered to be a volunteer firefighter for the purposes of subsection 81(4) and section 118.06. ...
Technical Interpretation - External summary
15 December 1998 External T.I. 9819355 - FOREIGN AFFILIATES - FOREIGN ACCRUAL TAX -- summary under Foreign Accrual Tax
. … [T]he U.S. tax paid by Usco on its share of the portion of the gain computed pursuant to the Code from the disposition of the Consideration Property by the Partnership that could reasonably be regarded as the gain and/or recaptured depreciation determined pursuant to the Code that was deferred on the disposition of the Rental Property by the Partnership would qualify as FAT. ...
Technical Interpretation - External summary
10 June 2016 External T.I. 2015-0587131E5 F - Remboursement de frais de repas -- summary under Paragraph 6(1)(a)
. … [W]here an employee incurs meals expenses for travel outside the municipality or metropolitan area [of the employer's establishment] and the employee is reimbursed by the employer, this amount is not included in the calculation of employment income because this travel mainly benefits the employer. ...
Technical Interpretation - External summary
27 July 2016 External T.I. 2015-0603271E5 - Subsection 216.1(1) and permanent establishment -- summary under Subsection 216.1(1)
. … ...
Technical Interpretation - External summary
27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB -- summary under Subparagraph 53(2)(c)(v)
27 June 2016 External T.I. 2016-0637341E5 F- Partnerships- Negative ACB-- summary under Subparagraph 53(2)(c)(v) Summary Under Tax Topics- Income Tax Act- Section 53- Subsection 53(2)- Paragraph 53(2)(c)- Subparagraph 53(2)(c)(v) loan advances to a limited partner may give rise to immediate s. 53(2)(c)(v) grind Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at the beginning of the following year the LP effects a distribution of the applicable share of the previous year’s profits to the limited partner by issuing a demand note to it and pays that note by way of set-off against the loans owing by the limited partner. ...
Technical Interpretation - External summary
27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB -- summary under Subsection 40(3.1)
27 June 2016 External T.I. 2016-0637341E5 F- Partnerships- Negative ACB-- summary under Subsection 40(3.1) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.1) loans by LP to partner potentially gave rise to negative ACB gain Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at the beginning of the following year the LP effects a distribution of the applicable share of the previous year’s profits to the limited partner by issuing a demand note to it and pays that note by way of set-off against the loans owing by the limited partner. ...
Technical Interpretation - External summary
12 May 2016 External T.I. 2014-0552341E5 - Subsection 107(4.1) -- summary under Subsection 107(4.1)
. … The fact that property was received from the Vendor in a fair market value purchase will not be relevant... ...
Technical Interpretation - External summary
8 November 2016 External T.I. 2016-0673361E5 - Section 230 of the Regulations -- summary under Subsection 230(3)
. … MFDA..or…AMF…), only the fund manager would be required to file T5008 slips with the CRA and provide a copy of the T5008 slip to the client. ...