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. … However, where subsection 15(2) and consequently Part XIII withholding tax had applied to a loan or indebtedness that is part of a Series of Loans, it will not apply again to the same amount of another loan or indebtedness in the Series of Loans. … Therefore, subsection 15(2) would not apply in respect of the New Loan such that the requirement in paragraph 15(2.11)(a) that the loan otherwise be subject to subsection 15(2) will not be satisfied. ...

CRA responded: [W]here a court orders one spouse to pay maintenance to another then, as regards the spouse to whom the court has granted the support, this is a situation respecting an entitlement a right arising out of the marriage of such spouses …. [T]he …. transfer [by X] was made under such a court order for the payment of maintenance to X and was intended to have the support granted to X under the court order be effected in in a more liquid form. ...

. … [A] travel allowance provided for in a an arm's length new contract would not be considered a re-characterization of an existing salary…where: the old contract has legally ended; the legal rights and obligations under the new contract designate (on a prospective basis) a portion of an employee's hourly compensation as a travel allowance; … the travel allowance is accounted for separately in the payroll system and on the employee's pay stub; and the terms of the new contract are reflected in the collective agreement (where the employee is represented by a union). ...

29 October 2013 External T.I. 2013-0501941E5- RCA transitional rule-- summary under Advantage Summary Under Tax Topics- Income Tax Act- Section 207.5- Subsection 207.5(1)- Advantage // www.parl.gc.ca/HousePublications/Publication.aspx?DocId=5765988&File=41 ">: Subsection 44(3) of Bill C-45 introduces anti-avoidance rules, s. 207.5, for RCA advantages and prohibited investments. ...

. … [I]f the taxpayer concerned has already filed his or her income tax return for the taxation year in question, the taxpayer … will then have to complete Form T1-ADJ, T1 Adjustment Request, duly completed or a signed letter that provides all the information concerning the taxpayer’s request to the taxpayer’s tax center. ...

29 May 2014 External T.I. 2014-0520851E5 F- Deferred Salary Leave Plan-- summary under Clause 6801(a)(iv)(B) Summary Under Tax Topics- Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(iv)- Clause 6801(a)(iv)(B) no requirement for employer to provide a return on the deferred amounts Would the condition in Reg. 6801(a)(iv)(B) be met if the agreement provides that the deferred amounts are held by the employer for the benefit of the employee (in an account separate from its own funds, or as part of its own funds) without ever providing a net return to the employee – in the former case, because it reduces the annual return by the annual administration costs incurred in managing the amounts in the separate fund? ... However, clause 6801(a)(iv)(B) does not require deferred amounts to be invested in funds separate from those of the employer, nor that a return on those amounts be provided under the terms of the DSLP agreement. … As to whether the employer can claim an annual administration fee for deferred amounts from the employee, there is nothing to prevent the employer from making such a claim. ...

For example, … where a DSU plan was terminated and all outstanding awards were redeemed in cash…[a]s the early redemption did not involve extraordinary circumstances…we took the position that the SDA rules applied retroactively with respect to any outstanding awards....The effect of these rules [in ss. 6(1)(a)(v), 6(11) and 248(1)- "deferred amount"] is to bring into income the current value of any rights that exist under an SDA at the end of each year that were not previously included in income. If an amount was includable in income in a year that is now statute-barred, … [this] result[s] in the amount being brought forward and included in income in the earliest non-statute-barred year. ...

. … If it is determined based on the facts that a DSU plan was never intended to provide for payments within the time parameters of paragraph 6801(d)… the SDA rules would apply retroactively. For example, … where a DSU plan was terminated and all outstanding awards were redeemed in cash…[a]s the early redemption did not involve extraordinary circumstances…we took the position that the SDA rules applied retroactively with respect to any outstanding awards. ...

7 January 2013 External T.I. 2012-0460021E5 F- Remboursement de cotisations à un club-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) where “membership in a fitness centre allows the employee to meet … specific conditions [of employment,” the test of “more than 50% … to the employer's advantage” may be met Are paramedics required to include a benefit in computing their income when their employer reimburses them for the cost of membership fees in a fitness centre? ...

. … Between the parties, a counter letter prevails over an apparent contract. … Generally, the CRA agrees to recognize a counter-letter for tax purposes to the extent that: the counter letter is concluded before or at the same time as the apparent contract and does not constitute an ex post facto arrangement; the counter-letter is not a sham; the counter-letter is disclosed to the CRA and the relevant documents are sent to the CRA at the appropriate time (usually when filing the relevant tax returns); the facts relating to the particular situation corroborate the parties' legal relationships to the counter-letter. ...