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. $6,000- [6000/(6,000 + 6,000) x $2,000]). The total U.S. tax paid in the year was $6080 (i.e. the taxable income for U.S. tax purposes of $16,000 multiplied by the U.S. tax rate of 38%) The portion of such amount that is applicable to the capital gain computed pursuant to Canadian tax law is in our view $2,316 (i.e. the proportion of the U.S. tax that the capital gain for Canadian tax purposes is of the U.S. taxable income before the application of the U.S. loss carry-forwards). … The portion of the $2,316 that would need to be considered reasonably applicable to the 1991 FAPI TCG in order to eliminate Canadian tax in respect thereof would be $1,900 as this amount multiplied by the relevant tax factor for the purposes of paragraph 91(4)(a) produces a deduction equal to the 1991 FAPI TCG ($5,000). A further deduction in respect of U.S. tax paid on the balance of the capital gain reported for U.S. tax purposes may be available under subsection 91(4) of the Act if the original disposition of the property gave rise to an income inclusion under subsection 91(1) of the Act in the 5 immediately preceding years. … The amount included in computing Canco's income in 1991 by virtue of subsection 91(1) of the Act in respect of the passive interest earned by FA after the deduction of the relevant portion of the deductible loss is $5,000 (i.e.$6,000-[6,000/(6,000 + 6,000) x $2,000]). ...

CRA stated: Provided there is clear evidence, at the time of the disposition of the excluded property, that arrangements are being made for the repayment (with due dispatch) of the "related debt"...the fact that the actual repayment of the debt occurs after the disposition of the excluded property would not, in and by itself, result in the debt not being considered "... related at all times... ". However if it was determined that other factors (such as cash flow problems, or unfavourable prevailing interest or exchange rates) contributed to the delay in repayment, it is likely that the provisions of paragraph 95(2)(i) would not apply on the repayment of the debt. ...

26 September 2013 External T.I. 2013-0497101E5 F- Avantage imposable consenti par un actionnaire-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) gift made by shareholder-manager to corporate employee “not received … on a purely personal basis” Is a gift received by an employee of a corporation from a shareholder manager, that would have been taxable under s. 6(1)(a) had it been provided by the corporation, taxable to the employee? In responding affirmatively, CRA stated: In order for a gift or benefit received by an employee to come within paragraph 6(1)(a), it is sufficient if there is some connection between the gift received and an office or employment of the taxpayer and that the gift was not received by the employee on a purely personal basis. … [E]verything indicates that the employee received the gift because of the employment held with the corporation. ...

Respecting the deductibility of the “meal” portion of the charges to the trainees, CRA stated: Paragraph 18(1)(h) explicitly precludes the deduction of personal or living expenses of the taxpayer in the calculation of the taxpayer’s business income …. According to [IT-357R2, para. 5] … any portion of a claim by a participant in respect of training expenses which either is personal or is unreasonable in the circumstances is not deductible by virtue of paragraph 18(1)(h) or section 67, respectively. ...

28 March 2013 External T.I. 2012-0465171E5 F- Frais médicaux- technicien en orthophonie-- summary under Paragraph 118.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) services of speech therapy technician ineligible After a physician’s referral, the taxpayer’s child (with a severe and prolonged impairment entitling the taxpayer to a credit for mental or physical impairment under s. 118.3) has been using the services of a speech-language pathologist in the private sector, who can only provide services to the child once every two weeks – so that for the other weeks, the child is seen by a specialized speech therapy technician to whom the child was referred by the speech-language pathologist. ... Thus, the fees paid to these technicians are not eligible …. ...

Thus … the hospitalization expenses … may be eligible medical expenses if the hospital in Country A is a public hospital or a private licensed hospital and the fees were paid for medical services. ...

. … [Here] … it appears that the move did not occur to enable the taxpayer to be employed at a new work location for purposes of the moving expense deduction. ...

4 June 2014 External T.I. 2013-0513761E5- Meaning of "cost" in determining "equity amount"-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(5)- Equity Amount- Paragraph (c) "cost" not reduced by amortization Generally, … the "cost" of property …include[s] the amount laid down to acquire such property. … The Queen v. ...

While…CRA… encourages taxpayers to keep original documents, … a person's statutory requirement to keep books and records can be met provided the content and the quality of the electronic image is sufficient to enable the taxes payable to be determined. … Although the guidance in [IC 05-1R1]… is generally intended to be used by businesses and other organizations, some of the guidance is relevant for individual taxpayers. ...

CRA responded: [In] determining the FMV of an interest in a professional partnership … [n]ormally, the work-in-progress of a business that was the subject of an election under section 34 is taken into account …. ...