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Technical Interpretation - External summary
24 September 2010 External T.I. 2010-0366661E5 F - Allocations de repas -- summary under Paragraph 6(1)(a)
. … On the other hand... a meal allowance to which an employee is entitled after working a certain minimum amount of overtime to be taxable if the payment to the employee is not truly related to whether or not the employee actually takes a meal. ...
Technical Interpretation - Internal summary
1 April 2010 Internal T.I. 2009-0352611I7 F - Redressement après le délai de prescription -- summary under Subparagraph 152(4)(a)(i)
1 April 2010 Internal T.I. 2009-0352611I7 F- Redressement après le délai de prescription-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) statement of incorrect income amount for spouse for s. 118(1)(a) credit purposes is a misrepresentation – but CRA must establish that prudent person would not have so erred Where a taxpayer claimed the married or common-law partnership tax credit (the "Tax Credit") and, after the taxpayer’s spouse was assessed beyond the normal reassessment period to add unreported income, can CRA also reassess the taxpayer beyond the normal reassessment period? ...
Conference summary
8 October 2010 Roundtable, 2010-0373221C6 F - Paid-up capital -- summary under Subsection 245(4)
. … The CRA has already concluded in some of these types of cases that avoidance transactions are caught by subsection 245(4) and that the general anti-avoidance rule applies. ...
Technical Interpretation - External summary
20 October 2010 External T.I. 2010-0377251E5 F - Canadian Controlled Private Corporation -- summary under Subsection 89(11)
After noting that in the absence of an s. 89(11) election, Corporation B became a CCPC on June 1, 20-A, CRA stated: [As] Corporation B did not make an election under subsection 89(11) to not be a CCPC until November 14, 20-B … the exception in paragraph (d) of the definition of CCPC in subsection 125(7) could only apply to Corporation B for the taxation year beginning on June 1, 20-A and ending on May 14, 20-B, and thereafter... ...
Technical Interpretation - External summary
9 November 2010 External T.I. 2010-0380661E5 F - Internal Reorganization -- summary under Subparagraph 55(3)(a)(ii)
In general … the exception in paragraph 55(3)(a) would appear to apply in respect of deemed dividends resulting from the cross-redemptions between Holdco Inc. and Holdco 2 Inc. ...
Conference summary
8 October 2010 Roundtable, 2010-0373691C6 F - T4A et T5018 - Honoraires -- summary under Subsection 238(2)
. … The GST, HST, QST or provincial tax portion, if any, of the amount paid should not be reported on the T4A slip since it is not an amount under subsection 153(1) and is not required to be included in computing the recipient's income under the Act. ...
Conference summary
8 October 2010 Roundtable, 2010-0371901C6 F - avantage à l'actionnaire, assurance-vie -- summary under Subsection 246(1)
. … [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...
Conference summary
8 October 2010 Roundtable, 2010-0371901C6 F - avantage à l'actionnaire, assurance-vie -- summary under Paragraph 12(1)(x)
. … [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...
Technical Interpretation - External summary
28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation -- summary under Know-How and Training
. … [W]here a source of income exists, either property or business income, reasonable training expenses incurred by a taxpayer to earn income from that source are generally deductible to the extent that they do not produce a lasting benefit to the taxpayer. ...
Technical Interpretation - Internal summary
12 January 2011 Internal T.I. 2010-0375801I7 F - Bien agricole admissible détenu avant 1987 -- summary under Subparagraph 110.6(1.3)(c)(ii)
The Directorate stated: [C]adastral lots are considered, for the purposes of the Act, to be separate real property …. ...