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Summaries of S1-F3-C2 under s. 54 – principal residence, Reg. 2301, s. 40(2)(b), s. 45(1)(c), s. 13(7)(b), s. 13(7)(e), s. 40(7) and s. 40(4). ...

Summary of 7 December 2016 Ruling 158637 under ETA s. 123(1) – supply, s. 182(1), and s. 232(1). ...

II, s. 1 – practitioner, and qualifying health care supply. ...

30 January 2017- 11:20pm CRA considers that no statute-barring applies to initial assessments of transfer-pricing penalties Email this Content In the situation where Canco acquires a non-depreciable capital property in Year 1 from an affiliate at a price that is substantially in excess of an arm’s length price, and then disposes of the property at a gain in Year 8 to a third party, CRA considers that a transfer pricing capital adjustment can be made to grind the adjusted cost base of the property in Year 1 even though that year is now statute-barred re Part I reassessments – and that, as “an initial assessment under subsection 247(3) can be made at any time,” a s. 247(3) penalty could be imposed re this Year 1 TPCA in the absence of reasonable efforts etc. ...

. … [N]o mortgage interest or…CCA…should be claimed. CRA also stated that the rents “would not generally be reported as rental income included on a T776.” ...

Summary of Sze Yee Ling and Nathan Wright, “Restrictive Covenants: Some Reminders,” Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 7 under s. 56.4(1) – restrictive covenant. ...

15 February 2017- 12:33am CRA takes an expansive view of what constitutes regular places of employment so as to render reimbursements for related travel as taxable benefits Email this Content CRA considers that if an individual has multiple regular places of employment (RPE) and travels between them during the day, the trip from the individual’s home to the first RPE and the trip home from the last RPE is personal, whereas travel between RPEs is considered employment-related – so that reimbursement of or allowances respecting the former but not the latter would give rise to employment benefits. ...

Summary of 2016 Ruling 2016-0639671R3 under s. 66.1(6)- Canadian exploration expense – para. ...

Summaries of Elie Roth, Tim Youdan, Chris Anderson and Kim Brown, "Classification of Trusts for Income Tax Purposes", Chapter 2 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016, including under s. 70(6)(b) and s. 149.1(1) – charitable foundation. ...

Summary of 2017 Quebec CPA Roundtable, Q.1.1, 2016-0674221C6 Tr under s. 123.4(1) – full rate taxable income. ...