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5 March 2015 External T.I. 2014-0553241E5 F- Bornes de recharge – avantage imposable-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) no benefit from free car-charging station An employer installs a charging station for electric vehicles at the workplace. ...

7 April 2015 External T.I. 2014-0552731E5 F- Apportez vos appareils personnels / BYOD-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) monthly payments re employee cell phone costs were allowances given no detailed receipts required Employees, who are required to use cell phones in the performance of their duties and to have their cell phone contracts approved by the employer, but bear the monthly costs of the contracts personally. ...

10 October 2014 APFF Roundtable Q. 4, 2014-0534831C6 F- 2014 APFF Roundtable, Q. 4- Late-filed 86.1 election & 220(3.5) penalty-- summary under Subsection 86.1(2) Summary Under Tax Topics- Income Tax Act- Section 86.1- Subsection 86.1(2) general principles applied to relief of s. 86.1 late-election penalties Is the making of a late election generally accepted without application of the penalty of $100 per month if the absence of a timely election is attributable solely to ignorance of the availability of the election or of the occurrence of an eligible distribution? ...

29 April 2015 External T.I. 2014-0532691E5 F- Vente – immeuble- syndicat copropriétaire-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation community of condominium owners is treated by the Civil Code as a legal person, and is a corporation A syndicate of co-owners holding condominium units sold one of the condominiums at a capital gain and distributed the gain to its members. ...

11 October 2013 Roundtable, 2013-0499671C6 F- Actif d'impôts futurs / Future income tax assets-- summary under Subparagraph (c)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (c)- Subparagraph (c)(i) future income tax asset is not an asset/tax receivable can be used in an active business Is a future income tax asset an asset used in an active business for the purposes of the definition of QSBC definition? ...

7 August 2015 Internal T.I. 2015-0585011I7- Osteopaths & naturopaths in Quebec-- summary under Subsection 118.4(2) Summary Under Tax Topics- Income Tax Act- Section 118.4- Subsection 118.4(2) Quebec osteopaths and naturopaths excluded in contrast to their eligibility for Quebec purposes Are osteopaths and naturopaths are authorized medical practitioners in the province of Quebec for purposes of the federal medical expense tax credit (METC)? ...

9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 3, 2015-0588951C6 F- Deductibility of interest – ss. 20.1(1)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) no source disappearance where interest-free advance to sub is forgiven The sole shareholder of a CCPC uses borrowed funds to make an interest-free advance to the CCPC, and the CCPC then makes a proposal under the BIA, which is accepted by the creditors and entails the shareholder advance being cancelled. ...

9 October 2015 APFF Roundtable Q. 20, 2015-0595681C6 F- Avantages imposables / dépenses d’entreprise-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) employer-provided parties, bike stands and internal recreation areas generally not taxable benefits It is "the CRA’s position is that when an employer offers free-of-charge, to all employees, a party or other social event, there is no taxable benefit if the cost per party or other social event does not exceed $100 per person. ...

16 November 2015 External T.I. 2014-0529361E5- Spousal trust & life insurance-- summary under Paragraph 73(1.01)(c) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(1.01)- Paragraph 73(1.01)(c) funding of life insurance policy is a benefit where proceeds to be paid to non-spouse In finding that the use of income or capital from a purported spousal trust to pay life insurance premiums on spouse's life would disqualify trust from inception, CRA stated: [T]he relevant legislation does not contain a requirement that the spouse “benefit” from the trust while alive.... ...

2 October 2015 External T.I. 2012-0463801E5 F- Déduction pour gain en capital – permis de pêche-- summary under Paragraph 110.6(1.3)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(b) para. ...