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Summary of 22 September 2017 External T.I. 2016-0668041E5 under s. 248(1) – taxable Canadian property – (d) and Treaties – Articles – Art. 13. ...

5 May 2024- 10:58pm CRA indicates that it will follow Gardner (re deducting a sales person’s expenses of occasional travel between her home office and her employer) only on similar facts Email this Content Regarding the deductibility of automobile expense incurred by an employee, with a fully remote work arrangement, in connection with an occasional visit to the employer’s 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. CRA noted that 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)” but indicated that it had not changed its position except “where it can be established that an employee’s circumstances are factually similar to Gardner and all of the requirements in paragraph 8(1)(h.1) and subsection 8(10) … are met.” ...

Points made by CRA include: “Competence … to practise” means that the mooted vocational or trade “course has a direct link to skills that are recognized by the CRA as relating to an individual’s ability to gain or retain employment.” ... An example of training that is not zero-rated is safety training provided to employees of a non-resident forestry company: “While stand-alone industry safety courses may be beneficial … on their own they would not be considered to lead to an occupation … and … do … not lead to a diploma or certificate attesting to the competence of the individual to practice a trade or vocation.” ...

Summaries of S3-F4-C1 under s. 18(1)(b) – capital expenditure v. expense – improvements v. repairs or running expenses, s. 13(21) – UCC – A, s. 13(21) – depreciable property, s. 16.1(1), s. 13(28), s. 13(27), Reg. 1100(2.2). 18(3.1), s. 13(7.5), s. 261(2), s. 68, s. 13(21.1)(a), s. 13(21.1)(b), s. 8(2), s. 13(9), s. 152(4), s. 13(5), and s. 13(6). ...

Summary of PJC Circular under Mergers & Acquisitions – Amalgamations – Triangular Amalgamations. ...

Summary of Power Financial Corporation Circular under Mergers & Acquisitions – Mergers – Privatizations. ...

(the “Purchaser”) under Mergers & Acquisitions – Mergers – Shares for Cash. ...

Summaries of Michael Black, "Cross-Border Consolidation and the Foreign Affiliate Rules," Canadian Tax Journal (2017) 65:1, 173-89 under Reg. 5907(1) – earnings – (a)(i), Reg. 5907(1) – taxable surplus, s. 95(1) – foreign accrual tax and Reg. 5907(1.3)(a). ...

Summary of Enercare Circular under Mergers & Acquisitions – REIT/Income Fund/LP Acquisitions – LP Acquisitions of Corporations – Exchangeable Units. ...

Is this excluded from income inclusion under s. 6(1)(b) by virtue of the exclusion in s. 6(1)(b)(vii.1) “for traveling in the performance of the duties of the … employment”? ... Amounts paid to the employee for such travel must therefore be included in computing the employee's income … [and] the employee cannot deduct personal travel expenses in computing income from an office or employment. ... Hogg, at para. 12) without regard to the underlying rationale, which is that if the employee incurs significant commuting expenses, that is a result of a personal decision to live at a distance rather than close to the employer’s establishment (see e.g., Cumming – “There may no doubt be [other] cases where a further element of personal preference for a more distant location has an appreciable effect on the amount of the expense involved”- or the House of Lords decision cited both by CRA and in Hogg: “They are incurred … because … living … away from Portsmouth, he must travel to that place before he can begin to perform his duties … and, having concluded those duties, desires to return home”), and that in a situation like this, the expense instead results from the employer’s business decision to have a second, more distant, work location. ...