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B are also subject to TOSI – thereby perhaps resulting (if she is an Ontario resident) in an effective tax rate of 107%. ... Summary of Stan Shadrin, Manu Kakkar and Alex Ghani, "FAPI and TOSI Overlap: 107 Percent Tax is Not Fair", Tax for the Owner-Manager, Vol. 20, No. 1, January 2020, p.5 under s. 120.4(1) – split income – (a). ...

(c) of the eligible remuneration definition excludes “any amount received [by the eligible employee] that can reasonably be expected to be paid or returned, directly or indirectly, in any manner whatever to … the eligible entity.” ... Summaries of 29 March 2021 Internal T.I. 2020-0865791I7 under s. 125.7(2) and s. 125.7(1) – eligible remuneration – (c). ...

Conversely, if it was determined that the corporation did not carry on a business, the excluded share exception would not apply – but s. ... Summary of 15 June 2021 STEP Roundtable, Q.4 under s.120.4(1) – excluded amount – s. ...

The Taxpayer has some autonomy within [the Agreement …] to recommend fees and rates to the acquirer with respect to the merchant agreements. ... Summary of 15 June 2021 GST/HST Interpretation 196187 under ETA s. 123(1) – financial service – para. ...

27 February 2022- 10:44pm CRA confirms that the Lavrinenko interpretation regarding a shared-custody parent has been legislatively overruled retroactively Email this Content While normally the Canada child benefit (CCTB) can at most be claimed by only one parent, individuals who are a child’s “shared‑custody parent” are each entitled to ½ of the benefit. ... Summary of 5 November 2021 External T.I. 2019-0812631E5 F under s. 122.6(1) – shared-custody parent – para. ...

A further concern is that any significant financing costs paid to non-residents (who are “tax-indifferent investors”) will also result in the loss of Canco’s excluded entity status – so that substantially all of Canco’s financing costs must be paid to other types of entities if it is to remain an excluded entity. ... International Tax Highlights (IFA Canada), Vol. 1, No. 2, August 2022, p. 7 under s. 18.2(1) – excluded entity – (c). ...

Summaries of 2016 Ruling 2014-0552321R3 F under s. 248(1) – disposition – (f), s. 74.4(4) and s. 108(1)- trust- (g). ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2017-09-13 21 July 2017 Internal T.I. 2017-0714931I7 F- Retiring allowance- Sick Leave Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance payout of accumulated (non-excess) sick leave credits on termination of employment was a retiring allowance Income Tax Act- Section 248- Subsection 248(1)- Death Benefit includes payout on death of accumulated (non-excess) sick leave credits Income Tax Act- Section 5- Subsection 5(1) payout on termination of accumulated sick leave credit is employment income to extent otherwise would have been paid at year end 2014-07-23 30 June 2014 External T.I. 2014-0522181E5 F- Legal status of partnership and application of 98(6) Income Tax Act- Section 98- Subsection 98(6) rollover on dissolution of general partner 2014-07-16 26 June 2014 External T.I. 2014-0523871E5 F- Revenu d'entreprise agricole Income Tax Act- Section 12- Subsection 12(10.2) government contributions and accrued interest in AgriInvest and Agri-Québec accounts are taxable when withdrawn Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(p) withdrawals from the AgriStability account are taxable as farm business income Income Tax Act- Section 248- Subsection 248(1)- Farming legume germination production as farming 23 June 2014 External T.I. 2014-0528271E5 F- Terrain « adjacent » à la résidence principale Income Tax Act- Section 54- Principal Residence meaning of immediately contiguous lands 27 June 2014 External T.I. 2014-0527341E5 F- Sociétés publiques aux fins de SPCC Income Tax Act- Section 89- Subsection 89(1)- Public Corporation Crown corporations not deemed to be public corporations 27 June 2014 External T.I. 2014-0526931E5 F- Vente d'une liste de clients par un employé Income Tax Act- Section 14- Subsection 14(5)- Eligible Capital Expenditure payment to departing employee for customer list was on capital account Income Tax Act- Section 6- Subsection 6(3)- Paragraph 6(3)(e) payment to departing employee for customer list was deemed income under s. 6(3) ...

., $1,800 = $1,000 + $800). Neal Armstrong. Summary of 20 January 2021 Internal T.I. 2019-0832211I7 under s. 126(1). ...

20 August 2020- 10:52pm CRA indicates that the two components received under a “face amount plus fund value” universal life policy are included in computing the corporate policy owner’s CDA Email this Content CRA indicated that where an exempt universal life held by Opco on the life of its shareholder paid two amounts to Opco on the death of the individual- the fund value of the policy (being the accumulated balance of the investment accounts within the policy at the time of the death of the life insured); and the face amount – the total of those two amounts would be “proceeds of a life insurance policy” for purposes of computing the increase to the capital dividend account of Opco. ... Summary of 8 July 2020 CALU Roundtable Q. 3, 2020-0842151C6 under s. 89(1) – capital dividend account – (d)(ii). ...