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Had this been the case, the $1,000 exemption would lose all of its meaning as it only applies to taxable income. … … [P]rovincial laws … such as legislation on labour standards or on occupational health and safety … [define] "volunteer firefighters" …. ... This approach allows some light to be shed on the meanings provincial government authorities accord to the expression as well as municipal or other public administrations. … [M]unicipalities and other public authorities are better able to determine the status of their employees. Paragraph 81(4)(b) states that this responsibility clearly falls on the shoulders of the municipality or public authority. … [On] an audit …[it] could be asked to … justif[y] its decision to grant … the exemption …. ...

Jan 1 1.50 Deposit US$100K from Cdn. bank account None – not a tax transaction Feb 1 1.40 Withdraw US$20K to buy shares Capital loss based on the excess of value of US$20K on Jan 1 compared to Feb 1 June 1 1.35 Deposit US$100 of dividends Dividend recognized based on 1.35 rate at dividend payment July 1 1.30 Deposit $20K of share sale proceeds Capital loss from disposition of $2,000 (their ACB of $28,000 (US$20,000 x 1.40) over the proceeds of $26,000 (US$20,000 x 1.30) Sep 30 1.20 Transfer US$50K to Cdn bank account The average exchange rate is 1.46, being the ratio of the total of each of the transactions in the bank account expressed in Cdn dollars [(150,000- 30,000 + 135 + 26,000) = 146,135] to the balance of that account in USD [(100,000- 20,000 + 100 + 20,000) = 100,100]. ...

29 August 2023 CPAC Roundtable Q. 8, 2023-0983051C6- Automobile Expenses-- summary under Paragraph 8(1)(h.1) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) Gardner (re deducting a sales person’s expenses of occasional travel between her home office and her employer) will be followed only on similar facts Regarding the deductibility of automobile expense incurred by an employee, with a fully remote work arrangement, in connection with an occasional visit to the office from the home office, CRA stated: [T]raveling between an employee’s home, including a home office, and a regular place of employment (RPE) is generally considered personal travel …. … In this case, “regular” means there is some degree of frequency or repetition in the employee’s reporting to that particular location in a given pay period, month, or year. … For example, a work location may be considered to be a RPE of an employee even though the employee may only report to work at that particular location on a periodic basis (e.g., once or twice a month) during the year. Depending on the circumstances, an employee may have more than one RPE. … … [Although] Gardner … held that motor vehicle expenses related to an employee’s travel between their home office and the employer’s principal place of business were deductible employment expenses under paragraph 8(1)(h.1) … the CRA’s general position on travel between an employee’s home or home office and a location that is a RPE for that employee remains unchanged. ...

CRA stated: The taxpayer's administrative policy for all officers and directors to reimburse the cost of a business class airline ticket in certain circumstances primarily benefits the employer. … [B]usiness class air travel may allow the employer to get better performance from the employee. Consequently … the reimbursement … does not constitute a taxable benefit …. … [T]he reimbursement of the spouse's ticket is made primarily for the benefit of the employee and … the latter derives an economic advantage from it. ... Thus … the reimbursement … is a benefit to be included in the employee's income under paragraph 6(1)(a). ...

ITRD will no longer consider any ruling requests pertaining to whether any given formula-based appreciation plan is a SDA, unless: i) the plan is of a type described in ATR-45 …; or ii) the ruling request pertains to whether one of the enumerated exceptions listed in the definition of SDA apply to the plan. … ITRD is increasingly concerned that the financial metrics that underlie formula-based appreciation plans may be susceptible to manipulation … [which] can be used to obfuscate the fact that a formula-based appreciation plan’s underlying purpose is to defer tax …. … [S]hare appreciation rights (“SAR”) plans … described in ATR-45 … [have] the following characteristics: The unit has no intrinsic value at the date of grant; The value of a unit is not guaranteed and may have a negative value after the date of grant; and The value of each unit at any particular time is determined by subtracting the FMV of a share of the employer at the date of grant from the FMV of a share of the employer at that particular time. ... This is because we consider such plans to be significantly less susceptible to manipulation …. … [O]ur decision to no longer consider ruling requests for formula-based appreciation plans does not mean that the CRA now considers all such plans to be SDAs. ...

. … [O]ur position that subsections 15(2) and (2.1) may apply to situations involving partnerships is consistent with the tax policy underlying the application of those subsections. … … CRA … appealed the Tax Court of Canada's decision. ...

CRA indicated: The definition of “Canadian resident partnership” … is not relevant for the application of [subpara. 2(f)] …. ... The CRA will in general consider that [subpara. 2(c)] … is satisfied even if a particular vendor is not directly involved in the negotiations for the sale of shares, when [the other conditions are satisfied]. … … T5013 forms … do … not constitute a return of income for the purpose of [subpara. 2(e)] …. ... Therefore, neither a partnership nor the partners of a partnership in situations such as described above may use the cost recovery method …. ...

11 May 2005 Roundtable, 2005-0127081C6 F- États financiers- Impôt de la Partie I.3-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) GAAP refers to Canadian GAAP Where a Canadian public corporation prepares its financial statements in accordance with US GAAP, will this be accepted as GAAP under s. 181(3)(b): CRA responded: GAAP refers to the current accounting standards or principles established by the … CICA …. … Where the balance sheet is prepared in accordance with U.S. ...

CRA responded: [A]n employer of a taxpayer makes contributions to a life insurance company that fall within the definition of RCA, the life insurance company is a custodian as [so] defined …. … [H]owever … a payment made to acquire an interest in a life insurance policy is not a contribution within the definition of RCA. ...

31 August 2005 External T.I. 2005-0114421E5 F- Frais de garde d'enfants-- summary under Child Care Expense Summary Under Tax Topics- Income Tax Act- Section 63- Subsection 63(3)- Child Care Expense fees for breach of contract can qualify but not educational fees CRA commented on whether the following categories of expenses incurred by parents at a childcare centre qualified as child care expense: fees paid for child care services yes additional fees paid for child care services generally yes – “fees for additional child care (where the parent picks up the child after official daycare hours) are child care expenses … provided they satisfy the other requirements of that section” outings outside the daycare no – “the purpose of those activities is not to look after the children in order to protect them and thus enable the parents to earn employment income … [but instead] is to ensure the development of the children's physical, social and artistic skills” classes and activities given at the daycare; no – “the primary purpose of those courses and activities is not to provide childcare but rather to promote the cultural, physical and artistic development of the children.” fees incurred for breach of contract generally, yes – “ 2003-0183697 … [indicated] that the phrase ‘an expense incurred...for the purpose of providing… child care services’ found in subsection 63(3) was broad enough to include expenses incurred for the breach of a contract. This conclusion is valid as long as these costs are the result of an undertaking required of the parents in order for the child care to be provided.” interest charges paid by parents who pay their bills late no – these are not “charges that are … paid to provide childcare but rather to compensate the childcare centre when a parent fails to make a payment by the agreed date” annual dues for parents wishing to be on daycare's Board no fees for sunscreen and insect repellent yes ...