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. … [W]here an employee sleeps in the truck cab, it is unlikely that the allowances for accommodation expenses in the three scenarios provided will be considered reasonable for the purposes of paragraph 6(1)(b). ...

Summaries of 14 October 2016 Interpretation 170549 under ETA s. 273(1), s. 240(3)(a), s. 169(1) and General Concepts – Agency. ...

II, s. 1 – health care facility- (a). ...

Ltd, ITA No.555/Ahd/2016 under Treaties – Art. 12. ...

Summary of 9 December 2016 External T.I. 2016-0639481E5 under s. 233.3(1) – specified foreign property. ...

7 February 2017- 11:46pm CRA confirms that taxpayers paying U.S. taxes through a Canadian trust or partnership are relieved from documenting support for their FTC claim (if T3 or T5013 issued) Email this Content At the 2016 STEP Roundtable, Q.9 (and later, at the 2016 annual CTF Conference, Q.12), CRA indicated that it had ceased exempting claims for U.S. foreign tax credits from the approach, which it already had been applying to FTC claims for other jurisdictions, of requiring a copy of the foreign tax return as well as a copy of the foreign notice of assessment (or other equivalent document) from the foreign tax authority – but that, in response to feedback on this change, it had begun to accept proof of payment to (or refund from) the foreign tax authority, rather than insisting on something like a notice of assessment. ...

8 February 2017- 11:42pm CRA indicates that s. 13(7)(e) applied to a s. 107(2.1) distribution but not a s. 104(5) deemed disposition Email this Content CRA agreed that the ½ step-up rule in s. 13(7)(e) does not apply to a deemed disposition under s. 104(5) given that the trust is not related to itself and does not otherwise not deal at arm’s length with itself. ...

Summary of Short Form Supplemented PREP Prospectus of TransCanada Trust under Offerings – Trust Notes. ...

Although ETA s. 296(2) requires CRA on audit to deduct any unclaimed ITCs from an assessment of net tax, CRA considers its usual approach described above to be “administrative relief” because, as a technical matter, “the tax payable [under s. 228(4)] is not part of the registrant’s net tax calculation” – so that in CRA’s view it is in its discretion as to whether, in addition to assessing the purchaser’s s. 228(4) tax, it also assesses the purchaser’s negative net tax resulting from recognizing the unclaimed ITC. ...

CRA considers that if there are two separate additions, an election must be made on each separately and each addition will fall into a separate class – whereas if the work on a single addition extends over more than one year (or there is a subsequent second addition to further extend the first addition), the election can be made at the end of the first year with respect to the work done to date (although this might have no immediate impact under the available-for-use rules) and the subsequent work will fall into the same separate deemed new class without any need to make a second election. ...