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Technical Interpretation - Internal summary
27 September 2016 Internal T.I. 2015-0572901I7 - Deferral of employment benefit under ss. 7(8) -- summary under Paragraph 73(1.01)(b)
. … [W]here capital property is transferred by Taxpayer A to Taxpayer B in settlement of rights arising out of their marriage or common-law partnership (see paragraph 73(1.01)(b) and subsection 73(1)), Taxpayer A will be deemed to have disposed of the shares for proceeds equal to Taxpayer A’s adjusted cost base (ACB) of the shares immediately before the disposition. ...
Technical Interpretation - Internal summary
15 November 2016 Internal T.I. 2016-0656351I7 - Corporate Minimum Tax Eligible Loss Calculation -- summary under Subsection 58(2)
. … In conclusion, a corporation that becomes subject to CMT will be required to determine its eligible losses for a particular taxation year as if it had been subject to CMT in previous taxation years. ...
Technical Interpretation - Internal summary
11 September 2015 Internal T.I. 2015-0586301I7 - Premiums received on re-opening of debt -- summary under Variable E
. … [T]he premiums received by the Taxpayer could now fall within amended variable E of the definition of CEC, assuming that the amounts…have [not] reduced the amount of an outlay or expense, (i.e., …if a reduction to paragraph 20(1)(c) did not apply as discussed above.) ...
Technical Interpretation - Internal summary
9 August 2016 Internal T.I. 2014-0526171I7 - Resettlement of a Trust -- summary under Paragraph 111(1)(a)
. … [T]he transaction changed the whole substratum or “raison d’etre” of the Trust. ...
Technical Interpretation - Internal summary
30 March 2016 Internal T.I. 2014-0547931I7 F - Voyages offerts par une compagnie -- summary under Subsection 200(1)
CRA indicated that the company providing the trips should issue T4A slips to the individual proprietor, or to the individual receiving the trip as a benefit qua employee of the individual’s personal corporation – whereas no T4A slip is required if the trip was received as a benefit qua shareholder of the personal corporation (a distinction which in practice would be difficult or impossible for the trip provider to apply). ...
Technical Interpretation - Internal summary
5 May 2009 Internal T.I. 2009-0311211I7 F - Impôt payable par ailleurs en vertu de la Partie I -- summary under Subsection 117(1)
In this regard, the T2 Corporation Income Tax Guide … states that the Part I tax payable for the year is the basic Part I tax plus the amount of surtax, the amount of recapture of the investment tax credit, and the refundable tax on the Canadian-controlled private corporation’s investment income, minus any allowable deductions and credits, including the federal tax credit for forestry operations. ...
Technical Interpretation - Internal summary
2 September 2009 Internal T.I. 2009-0329251I7 F - Application du paragraphe 80(16) -- summary under Subsection 80(16)
The TSO proposed to designate pursuant to s. 80(16) the maximum amounts permitted under ss. 80(7) and (11), so that the forgiven amount would be applied first against the balance of the non-capital loss, second as to reduce ¾ of the cumulative eligible capital and third, to reduce the adjusted cost base of the related corporation shares under s. 80(11), resulting in an amount being deemed to be a capital gain from the disposition of capital property under s. 80(12). ...
Technical Interpretation - Internal summary
30 November 2009 Internal T.I. 2009-0344051I7 F - Pénalités visées par 162(7), (7.01) et (7.02) -- summary under Subsection 162(7.01)
The Directorate first stated: Although the T5003 "Tax Shelter Information Return" and the T5003 "Statement of Tax Shelter Information" slips are considered interdependent … each summary and slip is a separate information return. ...
Technical Interpretation - Internal summary
8 February 2010 Internal T.I. 2009-0352721I7 F - Allocations pour frais de repas -- summary under Subparagraph 6(1)(b)(vii)
. … [W]ith respect to meal allowances paid to employees who work outside their regular place of employment, it is necessary to determine whether the allowance is reasonable and whether it is paid while the employee is travelling in the course of performing the duties of the employee’s employment outside the municipality or metropolitan area where the employer's establishment in which the employee ordinarily works is located. ...
Technical Interpretation - Internal summary
22 January 2010 Internal T.I. 2009-0346971I7 F - Événement ayant lieu dans un club de golf -- summary under Paragraph 67.1(2)(f)
In 1998, the Canada Revenue Agency amended its policy …. Consequently, a facility does not include a golf club's dining room, reception rooms, conference rooms, lounges or bar so that the deduction of expenses incurred for the purchase of food and beverages at a golf club is no longer prohibited by subparagraph 18(1)(l)(i). ...