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13 June 2008 External T.I. 2008-0270721E5 F- Allocations pour l'usage d'un véhicule à moteur-- summary under Subparagraph 6(1)(b)(vii.1) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) allowance for employees’ to return to work after regular shift to be on call was taxable In accordance with their collective agreement, employees are paid an allowance as compensation for the use of their personal vehicle when the employee is on call and must return to work after the employee’s regular shift in order to respond to calls – with the amount of the allowance based on what would have been disbursed had the employee instead returned to work by taxi. ...

15 July 2008 External T.I. 2008-0279271E5 F- Frais de déménagement en cas de faillite-- summary under Subsection 128(2) Summary Under Tax Topics- Income Tax Act- Section 128- Subsection 128(2) as s. 128 is a complete code not covering moving expenses, an individual could deduct moving expenses incurred in the stub pre-bankruptcy year from bankruptcy year income In finding that moving expenses incurred by an individual in the year that was deemed to end immediately before the day of bankruptcy could be deducted in the taxation year commencing with the bankruptcy and ending on December 31, CRA stated: [S]ection 128 is a complete code and … there are no rules preventing an individual from deducting qualifying moving expenses in the year of bankruptcy where those expenses were incurred in the year immediately preceding the bankruptcy. ...

CRA stated that where the “travel is between the Corporation’s place of business and another place of work … such travel is not of a personal nature” (and also noted that an allowance paid in accordance with the Reg. 7306 rates is generally considered reasonable). ...

X should compute her ½ share of the rental income or loss from both units whereas “Ms. ...

. … Since, in the example submitted, the net income is nil, no income or loss can be allocated to the retired partner. ...

. … [T]he circumstances do not allow us to conclude that the interest-free loan granted by the operating corporation allows it to earn income. ...

. … A business loss can be generated by electing to exclude WIP under section 34. ...

Thus … the amounts paid under the Program will not be taxable to those who receive them. ...

. … The definition of "qualifying educational program" in subsection 118.6(1) excludes a student who receives a benefit in respect of the program fees. ...

. … [I]n the above situation that condition is not satisfied since the amount invested in shares is immediately returned to the shareholder. ...