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Technical Interpretation - External summary
28 June 2010 External T.I. 2010-0357081E5 F - Crédit d'impôt pour la rénovation domiciliaire -- summary under Paragraph (b)
. … If the move occurs after the eligible period, in this example in March 2010, the unit will not be an eligible dwelling of the individual or a qualifying relation of the individual since it will not have been ordinarily occupied during the eligible period. ...
Technical Interpretation - Internal summary
24 January 2011 Internal T.I. 2010-0390111I7 F - GRIP Computation and Taxable Income for M&P Credit -- summary under Subsection 89(7)
. … It is clear to us, having regard to the provisions of elements I and J of element B of the formula in the definition of GRIP, that the MPPD Amount for a taxation year is not taken into account for purposes of the calculations. ...
Technical Interpretation - Internal summary
15 March 2010 Internal T.I. 2009-0323081I7 F - Frais pour droit d'usage -- summary under Element B
CRA stated: [T]here is no taxable benefit where an employee uses an Employer's automobile to drive from his or her home to the … customer. ...
Conference summary
4 May 2010 Roundtable, 2010-0359401C6 - Rebate Paid by an Advisor to a Policyholder -- summary under Element A
. … The [s. 53(2.1)] election generally allows the taxpayer to elect to reduce an amount that would otherwise be included in income pursuant to paragraph 12(1)(x), by reducing the adjusted cost base of the property in question by the amount so elected pursuant to paragraph 53(2)(s). ...
Technical Interpretation - External summary
19 May 2010 External T.I. 2010-0357071E5 F - Crédit d'impôt pour l'achat d'une 1e habitation -- summary under Subparagraph (a)(i)
19 May 2010 External T.I. 2010-0357071E5 F- Crédit d'impôt pour l'achat d'une 1e habitation-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 118.05- Subsection 118.05(1)- Qualifying Home- Paragraph (a)- Subparagraph (a)(i) given future intention test, there can be a gap between purchase and home becoming principal residence Can an individual otherwise satisfying the conditions claim the HBTC if the individual acquired a residence on December 15, 2009, but did not live in it before February 1, 2010 (and may have renovated it during that period) – and can there be a gap between the time of the home’s purchase and it becoming the individual’s principal place of residence? ...
Conference summary
29 November 2016 CTF Roundtable Q. 7, 2016-0672091C6 - GAAR Assessment Process -- summary under Subsection 245(2)
Where the matter instead has not been previously considered by the GAAR Committee, and the GAAR is likely going to be an assessment position, the TSO will refer the matter to Headquarters prior to issuing the proposal letter – so that it would generally only issue a proposal letter if Headquarters recommends GAAR’s application. ...
Technical Interpretation - External summary
6 December 2016 External T.I. 2015-0589041E5 F - Frais médicaux payés d’avance - prepaid medical expenses -- summary under Subsection 118.2(1)
. … For example, where an individual chooses the period from January 1 to December 31, 2016…[i]f the…fees were paid on December 31, 2015, they would not be eligible for the METC computation for the 2016 taxation year…. ...
Technical Interpretation - Internal summary
25 October 2016 Internal T.I. 2016-0658241I7 - Application of 95(2)(a.1) to a capital gain -- summary under Subparagraph 95(2)(a.1)(iv)
.] … Variable B of the FAPI definition applies specifically to capital gains, whereas income from a business other than an active business, such as income from the sale of property which meets the conditions of paragraph 95(2)(a.1), would fall under variable A of that definition. ...
Technical Interpretation - External summary
19 December 2016 External T.I. 2016-0643191E5 F - Deferred Salary Leave Plan (DSLP) -- summary under Paragraph 8(1)(n)
19 December 2016 External T.I. 2016-0643191E5 F- Deferred Salary Leave Plan (DSLP)-- summary under Paragraph 8(1)(n) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(n) deduction where “repayment” of advances made during employee leave In the course of a comprehensive discussion of the deferred salary leave plan (“DSLP”) rules in Reg. 6801(a), CRA provided an example of an arrangement in which, during an employee leave, the employee first receives amounts whose recognition was deferred under the DSLP rules, and then receives advances of salary or wages which are to be earned after returning – with CRA stating that both types of amounts “must be included in the employee's income in the leave year under subsections 6(3) and 5(1).” ...
Technical Interpretation - External summary
19 January 2017 External T.I. 2015-0576751E5 F - Trust, Disposition of depreciable property, Assumption -- summary under Paragraph 13(7)(e)
. … [T]he context and wording of the preamble to subsection 107(2.1) and paragraph (c) of the definition of disposition in subsection 248(1) provide a basis for concluding that the trust is deemed to have disposed of the property in favour of the beneficiary by virtue of paragraph (a) and that, under paragraph (b), the beneficiary is deemed to have acquired the property of the trust. ...