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4 December 2013 External T.I. 2012-0465891E5 F- Primes d'assurance / Premiums-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) insurance premium benefits qua shareholder When asked whether there would be a taxable benefit where Corporation A, which had other insured employees as well, paid insurance premiums for life insurance policies and disability policies covering Mr. ...

3 March 2015 External T.I. 2014-0519981E5 F- Donation avec charge / Gift with a charge-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) gift of encumbered property An individual donates a real estate property with a fair market value of $200,000 that is charged with a hypothec of $100,000. ...

17 December 2013 External T.I. 2013-0510371E5 F- MCIA / CEC-- summary under Subsection 24(1) Summary Under Tax Topics- Income Tax Act- Section 24- Subsection 24(1) fmv reduction of eligible capital property to nil does not trigger loss if business still carried on A taxpayer acquired franchise rights which subsequently became worthless as a result of the bankruptcy of the franchisor. ...

5 March 2015 External T.I. 2014-0553241E5 F- Bornes de recharge – avantage imposable-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) no benefit from free car-charging station An employer installs a charging station for electric vehicles at the workplace. ...

7 April 2015 External T.I. 2014-0552731E5 F- Apportez vos appareils personnels / BYOD-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) monthly payments re employee cell phone costs were allowances given no detailed receipts required Employees, who are required to use cell phones in the performance of their duties and to have their cell phone contracts approved by the employer, but bear the monthly costs of the contracts personally. ...

29 April 2015 External T.I. 2014-0532691E5 F- Vente – immeuble- syndicat copropriétaire-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation community of condominium owners is treated by the Civil Code as a legal person, and is a corporation A syndicate of co-owners holding condominium units sold one of the condominiums at a capital gain and distributed the gain to its members. ...

16 November 2015 External T.I. 2014-0529361E5- Spousal trust & life insurance-- summary under Paragraph 73(1.01)(c) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(1.01)- Paragraph 73(1.01)(c) funding of life insurance policy is a benefit where proceeds to be paid to non-spouse In finding that the use of income or capital from a purported spousal trust to pay life insurance premiums on spouse's life would disqualify trust from inception, CRA stated: [T]he relevant legislation does not contain a requirement that the spouse “benefit” from the trust while alive.... ...

2 October 2015 External T.I. 2012-0463801E5 F- Déduction pour gain en capital – permis de pêche-- summary under Paragraph 110.6(1.3)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(b) para. ...

6 May 2016 External T.I. 2016-0646411E5- Professional corporation & small business deduction-- summary under Specified partnership income Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified partnership income rulings for the multiplication of the small business deduction by professionals’ service corps will cease to apply CRA noted that the 2016 Budget proposes to extend the specified partnership income rules to partnership structures in which a Canadian-controlled private corporation (“CCPC”) provides (directly or indirectly, in any manner whatever) services or property to a partnership during a taxation year of the CCPC where, at any time during the year, the CCPC or a shareholder of the CCPC is a member of the partnership or does not deal at arm’s length with a member of the partnership (and that the Budget rules extend to comparable private corporation structures). ...

22 December 2016 External T.I. 2015-0608201E5 F- Capital distribution from trust & NR4-- summary under Regulation 202(1)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 202- Regulation 202(1)- Regulation 202(1)(c) all capital distributions made by Canadian-resident trusts to a non-resident beneficiaries must be reported on NR4s Does Reg. 202(1) require a Canadian-resident trust to report a capital distribution to a non-resident capital beneficiary? ...