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27 June 2016 External T.I. 2016-0637341E5 F- Partnerships- Negative ACB-- summary under Subsection 40(3.13) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.13) retention of partnership profits not a contribution 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. ...

Rulings that s. 107(2.1) applies to this transaction – but that ss. 53(2)(h)(i.1)(A) and 53(2)(h)(i.1)(B)(I) will apply such that the ACB of the Trust I Units to Subco will not be reduced by the amount of the capital gain which was thereby distributed to Subco, and that Subco will realize a capital loss. ...

. … Provided that the sum of the stub taxation years does not exceed 12 months, the CRA will accept the filing of the T106 form on June 30, 2017 (6 months after the December 31, 2016 year end). ...

. … Income allocation based on the ratio of distance traveled in a jurisdiction over the total distance traveled is generally not acceptable under subsection 126(2). ...

CRA responded: Since the income tax under subsection 204.1(2.1) is calculated monthly, at the end of the month … the time for calculating the cumulative excess amount in respect of RRSPs under subsection 204.2(1.1) and undeducted RRSP premiums under subsection 204.2(1.2) is at the end of each month. ...

CRA stated: [T]he term "program" used in the definition of "qualifying educational program" … refers to the program of study rather than to each individual course. ...

Consequently, we are of the view that in the situation you described to us, the cost of acquiring a laptop by the students who opted for the bundled purchase program does not qualify as tuition fees …. ...

9 May 2011 External T.I. 2010-0384711E5 F- Avantages imposables-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) allowance for gasoline expenses of forestry tree trimmers were taxable – limited exception for non-receipted reimbursement of safety equipment Allowances paid as expense allowances to contract forestry workers to reimburse the gasoline and oil expenses for their tree trimmers and calculated at a rate of 6% of the contracted price for their services in accordance with the industry practices, were taxable allowances An additional $5 per hectare is paid for safety equipment (boots, helmets, protective trousers and protective glasses and ear muffs) that the employee must procure was also a taxable allowance, except that: a reasonable allowance paid by the employer for the cost of protective clothing that an employee purchased without having to justify purchase by a receipt is non-taxable if all of the following conditions are satisfied: (i) the law requires the wearing of protective clothing on the site; (ii) the employee purchased the protective clothing; (iii) the amount of the reimbursement is reasonable. ...

Consequently, the amount of DPSP contributions that the employer pays to the trustee of the plan for the benefit of one of its employees should not be included in Box 14 of the T4 slip …. ...

. … Mrs. A will inherit the building, not as a principal residence, but as a rental property. ...