Search - 报销 发票日期 消费日期不一致

These are additions to our set of 3,139 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 24 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 3,159 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 24 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,202 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 24 ½ years of releases of such items by the Directorate. ...

T.I. 2015-0608051E5 F- Emigration of a trust Income Tax Act- Section 2- Subsection 2(1) Fundy Settlement test may differ from residence of trustees Income Tax Act- Section 220- Subsection 220(4.5) emigrating trust can elect to defer payment of the exit tax 2016-11-30 7 October 2016 APFF Roundtable Q. 1A, 2016-0652951C6 F- Penalty late filed election-subsection 85(8) Income Tax Act- Section 85- Subsection 85(8) penalty calculated on a global basis 7 October 2016 APFF Roundtable Q. 1B, 2016-0652761C6 F- T4A filing Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(g) limited exceptions to T4A reporting Income Tax Regulations- Regulation 200- Subsection 200(2) no expanded relief from the broad T4A reporting requirements 7 October 2016 APFF Roundtable Q. 1C, 2016-0652771C6 F- T106 and multiple year ends Income Tax Act- Section 231.1- Subsection 233.1(2) acquisition of control generally will not generate additional T106 filings 7 October 2016 APFF Roundtable Q. 2, 2016-0652841C6 F- Changement partiel d’usage- immeuble locatif et résidentiel Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(c) switch between which triplex units used for personal/family rental or 3rd-party rental did not trigger change of use Income Tax Act- Section 54- Principal Residence triplex contained separate housing units Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(b) on sale of triplex, individual can claim exemption only for years in which particular units were used personally or by children 7 October 2016 APFF Roundtable Q. 3, 2016-0652851C6 F- Annulation d'une promesse d'achat sur une maison Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(b) damages for breach of covenant to purchase principal residence not covered Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(b) no capital loss for damages paid for breach of purchase obligation 7 October 2016 APFF Roundtable Q. 4, 2016-0652801C6 F- Salary Deferral Arrangement Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangements- Paragraph (k) no backdating as of the year end 7 October 2016 APFF Roundtable Q. 5, 2016-0652861C6 F- Véhicules électriques- rabais Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A installation cost included Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(e) use of manufacturer’s electricity-use standard Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A cost not reduced under general principles by government assistance Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(g) vehicle assistance paid indirectly (to dealer) covered Income Tax Act- Section 6- Subsection 6(2) Quebec government assistance does not reduce cost of purchased vehicle, but treated as compensation to dealer-lessor prorated over term of lease 7 October 2016 APFF Roundtable Q. 6, 2016-0652821C6 F- Graduated Rate Estate- Total Charitable Gifts Income Tax Act- Section 84.1- Subsection 84.1(1) Poulin is consistent with CRA's previous statements on employee buycos Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) touchstones for accommodation party Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts- Paragraph (c)- Subparagraph (c)(ii) right of GREs to carry forward donations for five years 7 October 2016 APFF Roundtable Q. 7, 2016-0652971C6 F- Paragraph 251(5)(b) and subsection 256(1.4) Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b)- Subparagraph 251(5)(b)(i) right to find 3rd party purchaser Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b)- Subparagraph 251(5)(b)(ii) may include right arising after triggering of event over which no control Income Tax Act- Section 256- Subsection 256(1.4)- Paragraph 256(1.4)(a) does not include right to find a 3rd party purchaser for another’s shares 7 October 2016 APFF Roundtable Q. 9, 2016-0652921C6 F- Résidence- actif utilisé / Residence- asset used Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Share of the Capital Stock of a Family Farm or Fishing Corporation primary employee use qualifies farm house Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share farm house must be more than 50% used by farm employees to qualify 7 October 2016 APFF Roundtable Q. 10, 2016-0652931C6 F- Bien agricole admissible-saisine par succession General Concepts- Ownership estate owns its property Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(a)- Subparagraph 110.6(1.3)(a)(i) 3 owners if farm passes from father to estate to son 7 October 2016 APFF Roundtable Q. 11, 2016-0652941C6 F- Contrat de location / Capital lease Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share stipulated rights of lessee should be valued for QSBCS purposes Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation FMV of rights under a lease must be included 7 October 2016 APFF Roundtable Q. 12, 2016-0655911C6 F- Partial Leveraged Buy-Out and Monetization of ACB Income Tax Act- Section 84- Subsection 84(2) amalgamation does not cause reorg etc. of business 7 October 2016 APFF Roundtable Q. 13, 2016-0652981C6 F- Allocation of the safe income on hand Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) business income earned by a corporation following a subscription for a separate class of discretionary dividend shares could be allocated to those shares 7 October 2016 APFF Roundtable Q. 14, 2016-0655921C6 F- Safe income on hand- Preferred shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) fixed dividends on full-ACB prefs did not come out of SIOH Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) whether dividends paid on non-participating prefs engage s. 55(2) is a question of fact 7 October 2016 APFF Roundtable Q. 15, 2016-0652991C6 F- Application of subsection 55(2)- holding period Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) stock dividend of nominal value discretionary shares to shift value to an affiliate 7 October 2016 APFF Roundtable Q. 16, 2016-0653001C6 F- Safe income and freeze preferred shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) application of safe income on hand to dividends paid on estate freeze prefs 7 October 2016 APFF Roundtable Q. 17, 2016-0652781C6 F- Functional currency and acquisition of control Income Tax Act- Section 261- Subsection 261(9)- Paragraph 261(9)(a) exclusion of pre-transition debts from s. 111(4) Income Tax Act- Section 111- Subsection 111(4)- Paragraph 111(4)(e) FX gains or losses on pre-transition debts not affected Income Tax Act- Section 40- Subsection 40(10) exclusion of pre-transition debts 7 October 2016 APFF Roundtable Q. 18, 2016-0652791C6 F- Taxable Canadian property and Part XIII tax Income Tax Act- Section 119 property must have been TCP continuously from the time of emigration 7 October 2016 APFF Roundtable Q. 19, 2016-0655841C6 F- Reimbursement of attributed income Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) excess disposition proceeds not required to be repaid Income Tax Act- Section 74.1- Subsection 74.1(1) no domestic secondary adjustment doctrine Income Tax Act- 101-110- Section 103- Subsection 103(1) no obligation to repay income reallocated to other partner 7 October 2016 APFF Roundtable Q. 20, 2016-0655831C6 F- Employee Buycos and the Poulin Case Income Tax Act- Section 84.1- Subsection 84.1(1) Poulin accepted Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Poulin distinction between accommodation parties and tax advantaged arm’s length dealings accepted 7 October 2016 APFF Roundtable Q. 21, 2016-0655901C6 F- Section 7 and bonus paid in share Income Tax Act- Section 7- Subsection 7(1.1) 7(1.1) applicable to non-discretionary bonus payable in shares Income Tax Act- Section 84- Subsection 84(1)- Paragraph 84(1)(b) PUC of shares issued in satisfaction of bonus equal to bonus amount Income Tax Act- Section 7- Subsection 7(3)- Paragraph 7(3)(a) s. 7 can govern bonuses paid in shares where discretion ceases prior to the issuance 7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 1, 2016-0651771C6 F- Critical Illness Insurance Income Tax Act- Section 15- Subsection 15(1) benefit on gratuitous transfer of critical illness policy by corporation to its shareholder 7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2016-0651711C6 F- RRIF, Transfer of designated benefit Income Tax Act- Section 146.3- Subsection 146.3(6.11) computation of eligible amount following year of death Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(iii) capital loss recognition on land underlying duplex used 40% personally Income Tax Regulations- Regulation 1102- Regulation 1102(2) Reg. 1102(2) deems building to be separate from land and does not bifurcate the land Income Tax Act- Section 54- Personal-Use Property land underlying duplex used 40% personally is not personal-use property 7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 3, 2016-0651761C6 F- Transfer of a Life Insurance Policy Income Tax Act- Section 148- Subsection 148(7)- Paragraph 148(7)(a) s. 148(7)(a) prevails over s. 69(1)(b) and 52(2), but not s. 69(5) 7 October 2016 APFF Financial Strategies and Financial Instruments Roundtable Q. 4, 2016-0651791C6 F- Choix 45(2) et (3)- immeuble à logements Income Tax Act- Section 45- Subsection 45(3) invalidity of s. 45(3) elections on duplex units applied only for changes of use after February 21, 2012 ...

., as dividend income 9 October 2015 APFF Roundtable Q. 18, 2015-0595821C6 F- Ss. 96(1.01) and s. 103 Income Tax Act- 101-110- Section 103- Subsection 103(1.1) s. 103 can be applied to reallocate income to a deemed s. 96(1.01) partner 9 October 2015 APFF Roundtable Q. 19, 2015-0595621C6 F- Cash pooling and subsection 15(2) Income Tax Act- Section 15- Subsection 15(2.6) permitted use of FIFO to determine if debt repayments satisfy s. 15(2.6) 9 October 2015 APFF Roundtable Q. 20, 2015-0595681C6 F- Avantages imposables / dépenses d’entreprise Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) employer-provided parties, bike stands and internal recreation areas generally not taxable benefits 9 October 2015 APFF Roundtable Q. 21, 2015-0598291C6 F- Filing deadline for various forms Income Tax Act- Section 85- Subsection 85(1) where a return filing deadline falls on a Saturday, the deadline for the T2057 also is extended to the Monday Statutory Interpretation- Interpretation Act- Section 26 where a return filing deadline falls on a Saturday, the deadline for related forms also is extended to the Monday 9 October 2015 APFF Roundtable Q. 22, 2015-0598301C6 F- Extension of time to file Income Tax Act- Section 165- Subsection 165(1) extension of individuals' return deadline also extends objection deadline 9 October 2015 APFF Roundtable Q. 23, 2015-0598311C6 F- Excessive eligible dividend designation Income Tax Act- Section 185.1- Subsection 185.1(2) filing of s. 185.1(2) election in (non-prescribed) manner 9 October 2015 APFF Roundtable Q. 24, 2015-0598261C6 F- Calcul du revenu de placement total- annexe 7 Income Tax Act- Section 129- Subsection 129(4)- Aggregate Investment Income allocation of investment counselling fees as between interest and dividends 9 October 2015 APFF Roundtable Q. 25, 2015-0598321C6 F- Omission of deducting a dividend under 112(1) Income Tax Act- Section 152- Subsection 152(1) IC 75-7R3 still applies to requests for refunds for errors made in already-filed returns ...

Summary Descriptor 29 November 2016 CTF Roundtable Q. 1, 2016-0669301C6- GAAR & 21-year rule planning Income Tax Act- Section 245- Subsection 245(4) avoidance of 21-year rule through 107(2) transfer to corporate beneficiary Income Tax Act- 101-110- Section 104- Subsection 104(5.8) making a s. 107(2) distribution to a corporate beneficiary held by a new trust is an abusive circumvention of the s. 104(4) 21-year rule 29 November 2016 CTF Roundtable Q. 2, 2016-0669651C6- Computation of safe income Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(c) moratorium on providing interpretations on safe income allocation to discretionary dividend shares 29 November 2016 CTF Roundtable Q. 3, 2016-0670201C6- Agnico-Eagle Mines Decision Income Tax Act- Section 143.3- Subsection 143.3(3)- Paragraph 143.3(3)(b) application to coversion of debenture Income Tax Act- Section 39- Subsection 39(2) Agnico-Eagle analysis rejected 29 November 2016 CTF Roundtable Q. 4, 2016-0671491C6- 55(2) and Part IV Tax Income Tax Act- Section 55- Subsection 55(2) repeal of the s. 55(2) exemption, for dividends for which the Part IV tax is refunded on on-payment to an individual shareholder, busts integration Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (a) s. 55(2) application to dividend as a result of a Pt IV tax refund does not generate CDA for on-payment of that dividend 29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6- Investment management fees Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (a)- Subparagraph (a)(i) bearing of RRSP or TFSA fees by the annuitant or holder typically will be subject to the 100% advantage tax, effective 2018 29 November 2016 CTF Roundtable Q. 6, 2016-0669661C6- 84.1 and the Poulin/Turgeon Case Essentially the same question and answer as 7 October 2016 APFF Roundtable Q. 20, 2016-0655831C6 F- Employee Buycos and the Poulin Case-- summary under Paragraph 251(1)(c) Poulin distinction between accommodation parties and tax advantaged arm’s length dealings accepted 29 November 2016 CTF Roundtable Q. 7, 2016-0672091C6- GAAR Assessment Process Income Tax Act- Section 245- Subsection 245(2) whether a GAAR proposal letter is issued before a Headquarters/GAAR Committee referral generally turns on whether the GAAR issue is familiar 29 November 2016 CTF Roundtable Q. 8, 2016-0671501C6- 55(2) clause 55(2.1)(b)(ii)(B) Income Tax Act- Section 248- Subsection 248(1)- Property cash is property in s. 55(2) Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) cash is property for 55(2.1)(b)(ii)(B) purposes 29 November 2016 CTF Roundtable Q. 9, 2016-0669801C6- BEPS Action Item 13 Income Tax Act- Section 233.8- Subsection 233.8(3) no requirement to produce a Local or Master File Income Tax Act- Section 247- New- Subsection 247(4) BEPS 13 has no effect on the s. 247 documentation requirements 29 November 2016 CTF Roundtable Q. 10, 2016-0669751C6- U.S. ...

Expense- Know-How and Training convention expenses "historically" viewed as capital expenditures 6 October 2017 APFF Roundtable Q. 13, 2017-0709061C6 F- Calcul des frais pour droit d'usage Income Tax Act- Section 6- Subsection 6(2) s. 6(2) standby charge based on leasing cost to the employer rather than the automobile’s cost to an affiliated purchaser 6 October 2017 APFF Roundtable Q. 14, 2017-0720321C6 F- GAAR & 21-year rule planning Income Tax Act- 101-110- Section 104- Subsection 104(4)- Paragraph 104(4)(a) Act does not contemplate any deferral beyond 21 years while property is directly in a discretionary trust or through a Canco 6 October 2017 APFF Roundtable Q. 15, 2017-0709141C6 F- Designation pursuant to paragraph 111(4)(e) Income Tax Act- Section 111- Subsection 111(4)- Paragraph 111(4)(e) appreciated goodwill is now eligible for the s. 111(4)(e) step-up 6 October 2017 APFF Roundtable Q. 16, 2017-0709161C6 F- Résidence principale sur une terre agricole Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Interest in a Family Farm or Fishing Partnership- Paragraph (a)- Subparagraph (a)(i) a legally non-severable farm that is used both in farming and as a residence is one property for purposes of the s. 110.6 principal-use tests Income Tax Act- Section 248- Subsection 248(1)- Property non-severable farm is a single indivisible property 6 October 2017 APFF Roundtable Q. 17, 2017-0709171C6 F- Arm's length determination Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b)- Subparagraph 251(5)(b)(i) "holder-by-holder" method applied to treat contingent s. 251(5)(b) rights as being exercised re all the other shareholders 6 October 2017 APFF Roundtable Q. 18, 2017-0721691C6 F- APFF 2017- Question 18 Income Tax Act- Section 152- Subsection 152(1) DTS update ...

Topic Descriptor 29 May 2018 STEP Roundtable Q. 1, 2018-0744381C6- Update on the DTS 29 May 2018 STEP Roundtable Q. 2, 2018-0744101C6- Creation of a Trust Income Tax Act- 101-110- Section 104- Subsection 104(5.8) s. 104(5.8) applied where successive testamentary trusts created Income Tax Act- 101-110- Section 104- Subsection 104(4)- Paragraph 104(4)(b) 21-year rule’s application to testamentary trust is almost always computed from the testator’s date of death 29 May 2018 STEP Roundtable Q. 3, 2018-0744081C6- Trust return due date on wind up Income Tax Act- Section 249- Subsection 249(5) a non-GRE trust can have a calendar tax year even where it was dissolved Income Tax Act- Section 249- Subsection 249(1)- Paragraph 249(1)(c) non-GRE's tax year does not end with final distribution 29 May 2018 STEP Roundtable Q. 4, 2018-0743951C6- Safe income and estate Income Tax Act- Section 70- Subsection 70(6) safe income flow through on a spousal rollover of shares on death Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income flow through on a s. 70(6), but not s. 70(5), transfer 29 May 2018 STEP Roundtable Q. 5, 2018-0743961C6- Tax on Split Income Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares “income” means “revenue,” and incidental property revenue is assimilated to services revenue 29 May 2018 STEP Roundtable Q. 6, 2018-0743971C6- Excluded Shares – Holding Company Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares holding company shares do not qualify as excluded shares 29 May 2018 STEP Roundtable Q. 7, 2018-0744031C6- Excluded Shares Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares a corporation with only property income does not accord excluded share status 29 May 2018 STEP Roundtable Q. 8, 2018-0742141C6- Application of subsection 70(5) Income Tax Act- Section 70- Subsection 70(5) McKenzie statement, that s. 70(5) inapplicable to NRs, is not followed 29 May 2018 STEP Roundtable Q. 9, 2018-0744111C6- Vested Indefeasibly Income Tax Act- 101-110- Section 108- Subsection 108(1)- Trust- Paragraph (g) meaning of vested indefeasibly 29 May 2018 STEP Roundtable Q. 10, 2018-0748381C6- Pipeline Ruling Requests Income Tax Act- Section 84- Subsection 84(2) in a pipeline ruling, the business must be continued for 12 months 29 May 2018 STEP Roundtable Q. 11, 2018-0748241C6- Subsection 104(13.4) Income Tax Act- Section 75- Subsection 75(2) s. 75(2) does not apply to the deemed s. 104(4) capital gain arising in an alter ego trust on the life beneficiary’s death Income Tax Act- 101-110- Section 104- Subsection 104(6)- Paragraph 104(6)(b)- Element B- Subparagraph (i) s. 104(4) gain is taxable in an alter ego trust 29 May 2018 STEP Roundtable Q. 12, 2018-0748811C6- US Transition Tax Income Tax Act- Section 126- Subsection 126(1) generally Canadian residents who are subject to the U.S. transitional tax generally will not be entitled to a foreign tax credit 29 May 2018 STEP Roundtable Q. 13, 2018-0744161C6- 75(2) and Foreign Tax Credit Income Tax Act- Section 20- Subsection 20(12) US withholding taxes borne by s. 75(2) trust might reduce the attributed income amount Income Tax Act- Section 126- Subsection 126(1) U.S. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2018-12-12 5 October 2018 APFF Roundtable Q. 11, 2018-0768821C6 F- Tax on Split Income Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Amount- Paragraph (e)- Subparagraph (e)(i) dividends derived from stock portfolio of Holdco excluded because stock portfolio not a related business or not a business Income Tax Act- Section 120.4- Subsection 120.4(1)- Related Business- Paragraph (a)- Subparagraph (a)(i) stock market investing business of child's holdco not a related business as father not involved 5 October 2018 APFF Roundtable Q. 12, 2018-0768831C6 F- Tax on Split Income and Partnership Income Tax Act- Section 96- Subsection 96(1.8) having non-contributing children in a family portfolio investment partnership subject to potential challenge under ss. 74.1 and 96(1.8) Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (a)- Subparagraph (a)(i) family partnership investing in designated stock exchange shares not subject to TOSI rules Income Tax Act- 101-110- Section 103- Subsection 103(1.1) having non-contributing children as members of a family stock market partnership is subject to challenge under s. 103 5 October 2018 APFF Roundtable Q. 13, 2018-0778661C6 F- Tax on Split Income Income Tax Act- Section 120.4- Subsection 120.4(1)- Arm's Length Capital no exclusion for arm’s length capital contribution where contribution derived from capital gain from related business Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Amount- Paragraph (e)- Subparagraph (e)(i) amounts not derived from a business were excluded amounts Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares returns to a spouse and older children from a Holdco in which they reinvested their Opco capital gains exemption could qualify as excluded amounts 5 October 2018 APFF Roundtable Q. 14, 2018-0768851C6 F- Avantage imposable découlant de l’utilisation d’un aéronef Income Tax Act- Section 15- Subsection 15(1) shareholder benefit from corporate aircraft reduced by an interest-free loan made by the shareholder to fund its purchase 5 October 2018 APFF Roundtable Q. 15, 2018-0768861C6 F- Share exchange and statute of limitation Income Tax Act- Section 152- Subsection 152(4) a price adjustment clause can operate re statute-barred transactions to affect a tax attribute that is used in the current year General Concepts- Effective Date retroactive ACB adjustment under PAC to statute-barred transaction may be taken into account in a current relevant transaction 5 October 2018 APFF Roundtable Q. 16, 2018-0768871C6 F- Dépenses de bureau à domicile et d’automobile Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property depreciable property must be owned Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Incurring of Expense payment of expenses of taxpayer by another does not preclude “incurring” by taxpayer Income Tax Act- Section 9- Nature of Income payment of taxpayer’s expenses by another might give rise to s. 9 or 80 inclusion Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(g) example of proration of capped s. 13(7)(g) capital cost Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A capital cost of co-ownership interest 5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F- entreprise exploitée activement – revenu de location Income Tax Act- Section 125- Subsection 125(7)- Active Business Carried On by a Corporation question of fact whether a CCPC with too many employees to have a specified investment business carries on a business Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business principal purpose means main or chief objective 5 October 2018 APFF Financial Strategies and Financial Instruments Roundtable Q. 1, 2018-0761521C6 F- Life insurance policy as share redempt. proceeds Income Tax Act- Section 148- Subsection 148(7) more gain will be realized if an appreciated life insurance policy is distributed as redemption proceeds rather than a dividend-in-kind 5 October 2018 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2018-0765791C6 F- Tax on Split Income Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares- Paragraph (a)- Subparagraph (a)(i) shares of a rental property company potentially may qualify as excluded shares for TOSI purposes 5 October 2018 APFF Financial Strategies and Financial Instruments Roundtable Q. 3, 2018-0765801C6 F- Tax on Split Income Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (e)- Subparagraph (e)(ii) deemed s. 104(21) capital gains retained their character as stock market gains Income Tax Act- Section 120.4- Subsection 120.4(1)- Related Business- Paragraph (a)- Subparagraph (a)(ii) related business if children manage investment business of trust whose interest income is distributed to mother Income Tax Act- Section 120.4- Subsection 120.4(1.1)- Paragraph 120.4(1.1)(c)- Subparagraph 120.4(1.1)(c)(ii) s. 120.4(1.1)(c)(ii) exclusion where investment portfolio business of spousal trust had been carried on directly by deceased husband 5 October 2018 APFF Financial Strategies and Financial Instruments Roundtable Q. 4, 2018-0765811C6 F- Tax on Split Income Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (c)- Subparagraph (c)(ii)- Clause (c)(ii)(D) no TOSI on net rental income of spousal trust on properties managed by son if excluded amounts Income Tax Act- Section 120.4- Subsection 120.4(1.1)- Paragraph 120.4(1.1)(c)- Subparagraph 120.4(1.1)(c)(ii) exclusion where rental portfolio of spousal trust was a directly-conducted business of deceased husband 5 October 2018 APFF Financial Strategies and Financial Instruments Roundtable Q. 5, 2018-0761561C6 F- Rachat de parts en cas d’invalidité ...

These are additions to our set of 1,053 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¾ years of releases of Interpretations by the Directorate. ...