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22 December 2005 External T.I. 2005-0151091E5 F- Allocation de retraite- retenue à la source-- summary under Paragraph 100(3)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 100- Subsection 100(3)- Paragraph 100(3)(c) confirmation of RRSP deduction limit is not required from the employee for the portion of the retiring allowance that is eligible for deduction under paragraph 60(j.1) In response to a query as to whether the correspondent’s notice of assessment must be provided to the employer so that it can pay the retiring allowance amount into the individual’s RRSP without deductions at source – and whether that amount can be paid into a spousal RRSP or as a repayment of the individual’s home buyers' plan ("HBP"), CRA stated: [T]he employer is not required to withhold tax on the amount of the retiring allowance that it pays directly to an RRSP if the employer has reasonable grounds to believe that the premium is deductible under paragraph 60(j.1) or subsection 146(5) or (5.1) in computing the employee's income for the taxation year in which the retiring allowance is paid. ...

Consequently, subsection 83(2.1) would not apply to deem a capital dividend received by Ms Y … to be a taxable dividend. ...

Content Provider which relates to the streaming of the digital content to Canco’s subscribers to the extent that the right in or to the use of the digital content is being used or reproduced in Canada” – except that: Canadian withholding tax can still apply, should the right in or to the use of the digital content be partly used or reproduced in Canada prior to being streamed to these foreign subscribers for viewing outside of Canada (but only to the extent of the payment that is related to the use or reproduction in Canada) or if it was being streamed in Canada. ...

Would this dividend be characterized as income that is derived directly or indirectly from a related business for s. 120.4 purposes – and would the answer change if the dividend was paid before 2018? ...

After noting that such policy did not apply to cash equivalent gifts and awards, such as where the employee receives reward points, which are accumulated and can be redeemed for a choice of goods, CRA stated that there could be “arguments that the points may not constitute a cash or cash equivalent award … since the points cannot be converted into cash and the number of goods that the employee can acquire, in exchange for the accumulated points, is very limited.” ...

. … [I]n 2002, the partner did not elect to add back income from that business pursuant to subsection 34.1(2). ...

. … Where an employee elects to receive the amount of the retiring allowance in instalments, it is our view that the instalments will be taxable in the year they are received. ...

“Where participating shares are exchanged for preferred shares having a FMV and a redemption value equal to the FMV of the participating shares, and because of the application of subsection 51(1) to the exchange, the ACB of the preferred shares is equal to the ACB of the exchanged participating shares, then the portion of the income earned on hand attributable to the participating shares immediately before the exchange is transferred to the preferred shares” – so that $8 million safe income of the Class A shares transferred to the 10,000 Class B shares. ...

. … [T]he CCRA considers overtime to be of an occasional nature if it is worked less than three (3) times per week. ...

(j) thereof): [A] transfer of property to a trust that is made for the sole purpose of securing the repayment of a debt or a loan within the meaning of paragraph (j) of the definition of "disposition" in subsection 248(1) nevertheless constitutes a disposition of property for the purposes of the Act, unless the transfer is also described in one of paragraphs (f), (g) or (k) of the definition of "disposition" …. ...