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EMPLOI Income Tax Act- Section 60- Paragraph 60(n)- Subparagraph 60(n)(iii) repayment of EI benefits due to award of wrongful dismissal damages was deductible under s. 60(n)(iii) Income Tax Act- Section 60- Paragraph 60(v.1) repayment of EI benefits due to award of wrongful dismissal damages was deductible under s. 60(n)(iii) rather than s. 60(v.1) 14 March 2002 External T.I. 2002-0119695 F- Income & Losses/Business or Property General Concepts- Agency criteria applied for determining presence of agency 12 March 2002 External T.I. 2002-0125885 F- Section 55(3)(a)- Exception55(3)(a) Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a) s. 55(3)(a) applies where Opco redeems 50% shareholder (Holdco A) where other shareholder is owned by the son respecting the spousal trust owning Holdco A ...

These are additions to our set of 2,812 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 2,819 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¼ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-01-04 9 January 2002 External T.I. 2001-0089655 F- AVANTAGE AUTOMOBILE Income Tax Act- Section 248- Subsection 248(1)- Automobile- Paragraph (e)- Subparagraph (e)(i) 6-seat pickup not excluded from 90% test Income Tax Act- Section 6- Subsection 6(2) being on-call at home does not diminish the personal benefit from use 10 January 2002 External T.I. 2001-0090325 F- UTILISATION DES VEHICULES Income Tax Act- Section 6- Subsection 6(2) commuting in connection with employer requirement to keep vehicle overnight at home was personal use – but not emergency use 18 January 2002 External T.I. 2001-0092665 F- AUTOMOBILE-VEHICULE PUBLICITAIRE Income Tax Act- Section 248- Subsection 248(1)- Automobile automobile status turns on design, not use (here, only for advertising) Income Tax Act- Section 248- Subsection 248(1)- Automobile- Paragraph (e)- Subparagraph (e)(i) vehicle cosmetically altered for advertising purposes is not thereby used to transport goods or equipment 8 January 2002 External T.I. 2001-0094485 F- EMPLOI SUR UN CHANTIER PARTICULIER Income Tax Act- Section 6- Subsection 6(6)- Paragraph 6(6)(a) s. 6(6) applicable to a non-citizen 21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme Income Tax Act- Section 54- Proceeds of Disposition FMV of contingent right to deferred cash sales proceeds was included in proceeds, with subsequent gain or loss when the contingency was resolved Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) s. 12(1)(g) inapplicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration declined in value Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(f) s. 85(1)(f) applicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration received under s. 85(1) declined in value 21 January 2002 External T.I. 2001-0080325 F- FRAIS DE VOYAGE-BIENS LOCATIFS Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(h) notwithstanding s. 18(1)(h) jurisprudence, CCRA allows travel expenses incurred for collecting rent, supervising repair work or managing the multiple rental properties ...

These are additions to our set of 2,831 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,879 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,886 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,892 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,898 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,922 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...