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Principal Issues: taxable benefit relating to the waiving of bank service charges in the case of employees Position TAKEN: the benefit is taxable Reasons FOR POSITION TAKEN: the situation is not analogous to retail industry employee discounts, subsidization of an employer cafeteria & the amount of the benefit is clearly established by way of the amount charged to customers A. ...

Yours truly, for Director Financial Industries Division Income Tax Rulings and Interpretation Directorate Policy & Legislation Branch ...

Proper tax treatment for retiring partner who receives a retiring benefit + payments in respect of work in progress. 2. ...

Robertson in the 1981 Conference Report at p. 108 that "... the Department will generally review the transactions(s) or event(s) in terms of the absolute dollar increase in the interest in any corporation. ...

While not restricted to a Christmas party, it could provide an exception for costs relating to another function that is "... generally available to all individuals employed by the person at a particular place of business of the person... ...

Paragraph 122.3(1)(b) of the Act requires that the employee perform "... all or substantially all the duties of the individual's employment outside Canada... ...

Reasons: In accordance with subparagraph 6801(a)(i) & previous position taken. ...

Généralement, la Société devrait remplir un feuillet T4A-Supplémentaire si le paiement dépasse 500 $ pour un contribuable donné. ...

As noted in paragraph 6 of IT-280R "... Accordingly, for a plan with an 'out of profit' formula, the formula determining the employer's contributions must provide for a minimum contribution every year of the lesser of $100 per employee member and an amount calculated by, for example, reference to a percentage of the employee's annual contributions or salaries. ...

We apologize on behalf of the Canada Custom & Revenue Agency for the delay. ...