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Although it is a question of fact whether the employee's travel is personal or employment-related, it is the CRA's longstanding position, as noted in Chapter 2 of Guide T4130, Employer's Guide – Taxable Benefits and Allowances, that travelling between an employee's home and his or her regular place of employment (RPE) is personal travel. ...

The Regulations state that if the leave of absence (" Leave Period") is for the purpose of attending a designated educational institution on a full-time basis, the leave must be for at least 3 consecutive months. ...

4 March 2013 External T.I. 2011-0428661E5- trust payments to minor CRA Tags 104(18) 80 104(24) 75(2) Principal Issues: Discussion of making payments or making amounts payable to or on behalf of a minor from a trust & the application of 75(2) Position: No change in previous positions Reasons: Appears to be actual fact situation, so general comments given XXXXXXXXXX Lena Holloway, CA 613-957-8968 2011-042866 March 4, 2013 Dear XXXXXXXXXX: Re: Trust for Minor This is in reply to your email communication dated November 18, 2011 requesting our comments on the application of subsection 104(18) of the Income Tax Act (the "Act"). ...

The exception to the direct use test for borrowed money used by a corporation to redeem shares, return capital or pay dividends is described in paragraph 23 of IT-533 as follows: ¶ 23. ...

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

An objection is filed by using one of these options: online submission, by accessing "My Account" from the CRA website; select the option "Register my formal dispute"; or completing Form T400A, Objection – Income Tax available on the CRA website at: http://www.cra-arc.gc.ca/E/pbg/tf/t400a/t400a-12e.pdf. ...

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

On immigration to Canada, paragraphs 128.1(1)(b) and (c) of the Act generally provide for a deemed disposition of the individual's property (other than property described in subparagraphs 128.1(1)(b)(i) to– (v), – not applicable to this scenario) immediately before the time of immigration to Canada for proceeds equal to fair market value, and a deemed reacquisition of such property at a cost equal to the proceeds of disposition. ...

The CRA's general views related to the capital gains matters are largely discussed in Chapter 7 of Guide T4003 – Farming Income, Chapter 1 of the Guide T4037- Capital Gains, and paragraphs 20 to 24 of Interpretation Bulletin IT-120R6, Principal Residence. ...

Reasons: (i) The 1989 Conference Report and document # 9309585 did not state a PAC would negate the specified amount. ...