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Technical Interpretation - External summary
31 March 2014 External T.I. 2013-0513191E5 - Director/Executor liability -- summary under Subsection 159(3)
. … Finally, before making any distributions from the estate, the executor is required to obtain a clearance certificate, pursuant to subsection 159(2)…. ...
Technical Interpretation - Internal summary
12 February 2014 Internal T.I. 2012-0443391I7 - cross-border loans and deductibility of interest -- summary under Paragraph 20(1)(c)
…[T]he features described … in [the documentation], in and of themselves, would not cause the interest on the borrowed money to not be deductible.... ...
Technical Interpretation - External summary
21 May 2014 External T.I. 2014-0528021E5 - Classification of Timber Limits -- summary under Schedule VI
. … [T]he cost of land with standing timber characterized as a timber limit would be more appropriately included in Schedule VI rather than under Class 15 of Schedule IV…. ...
Technical Interpretation - Internal summary
3 March 2015 Internal T.I. 2014-0527841I7 F - Avantage imposable pour aéronef -- summary under Subsection 15(1)
(at para 42)) rather than their cost – although, here, the denied operating expenses and CCA of the corporate owner "can be used to establish the value of the benefit conferred on Mr. ...
Technical Interpretation - Internal summary
3 March 2015 Internal T.I. 2014-0527841I7 F - Avantage imposable pour aéronef -- summary under Paragraph 15(1.4)(c)
A's father, CRA indicated that there would be no taxable benefit respecting such use by the father for the years under review before the effective date of s. 15(1.4)(c) – but thereafter, the value of the benefit enjoyed by the father was taxable to the son (Mr. ...
Technical Interpretation - External summary
22 October 2012 External T.I. 2012-0452491E5 F - Repas fournis dans le cadre d'une formation -- summary under Paragraph 67.1(2)(a)
. … [T]he CRA would be inclined, in situations similar to those described in the judgment, to accord tax treatment similar to that provided by the TCC in its judgment. ...
Conference summary
5 October 2012 Roundtable, 2012-0451271C6 F - Residence of a trust -- summary under Subsection 2(1)
. … [T]he fact that a person advises a trustee should not in itself generally alter the location of central management and control of the trust at the trustee level. ...
Technical Interpretation - External summary
17 November 2014 External T.I. 2014-0555061E5 - Canada-Japan Income Tax Convention, Article 13 -- summary under Article 13
. … [T]here is nothing in the Treaty that expressly provides where a gain described in paragraph 4 of Article 13 arises. ...
Technical Interpretation - External summary
24 February 2014 External T.I. 2013-0505391E5 F - Clause de earnout renversé -- summary under Paragraph 12(1)(g)
., " the selling price initially is fixed at a maximum equal to the fair market value at the time of the sale, but... this sale price can be reduced in accordance with a pre-established agreement if certain conditions are not met" so that on such reduction no reimbursement of the sale price occurs): the actual proceeds of disposition are not determinable at the time of disposition of the shares. ...
Technical Interpretation - External summary
6 November 2014 External T.I. 2014-0530991E5 - Liability for the failure to withhold -- summary under Paragraph 153(1)(a)
. … [W]here the payor failed to remit amounts withheld or deducted, the payor…is liable for the amount of the deductions that were not remitted together with the penalty for not remitting, and interest thereon. ...