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After noting that “ T4130 … states that when an employer pays an allowance that is a combination of flat-rate and reasonable per-kilometre allowances that cover the same use for the vehicle, the total combined allowance is a taxable benefit and has to be included in the employee's income,” CRA stated: [P]art of the allowance paid to employees is based on a per kilometre rate that is considered reasonable while the other part of the allowance is not related to the use of the motor vehicle there are two allowances. ...

21 August 2008 External T.I. 2008-0272241E5 F- Régime compl. d'assurance de soins médicaux-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) a decrease in salary and increase in HCSA flex credits on renegotiation of employment contract does not result in an income inclusion Regarding employees who relinquish, once at the beginning of the year for their health care spending account, part of their salary increase in order to add additional credits, CRA stated: … IT-529 … states that if an employee forgoes an amount to which the employee is or will become entitled, such as a negotiated salary increase, vacation or bonus, the amount of remuneration forgone is included in income in the year in which the amount is converted to flex credits. ...

In confirming that this worked as a technical matter, but before noting the GAAR could be engaged, CRA stated: If it were determined that the gain or loss realized by Aco in respect of Options #1 and #2 was on capital account, we would be of the view that subsection 49(1) would apply in this case to the sale by Aco of Options #1 in the particular taxation year and that, in accordance with our position in paragraph 29 of … IT-479R … the cost to Aco of acquiring Options #2 at the beginning of the taxation year following the particular taxation year would be a capital loss incurred at that time. ...

. … Furthermore … the reason the employer rents an assembly area and provides transportation is to reduce the cost of maintaining the gravel road and the cost of damages it would incur if the employees' or independent contractors' cars were damaged due to the condition of the road. ...

CCRA stated: [T]he cost to the acquiring corporation of each share acquired would generally correspond to the total of the amount paid in cash and the amount added by the acquiring corporation to its stated capital account …. Consequently … the cost would be $10 per share acquired by Pubco. ...

23 August 2001 External T.I. 2001-0086235 F- CONVENTIONS FISCALES A.18-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 QPP and OAS were pension payments made under social security legislation for purposes of the Slovenia and Croatia treaties Regarding the tax treatment of QPP and OAS payments made to residents of Slovenia, Croatia and Germany, CCRA indicated that: Under the Slovenia Convention, since “pension” was not defined, its meaning under s. 5 – pension – (a)(ix), of the ICTCIA applied to render them pension payments. ...

. … S4-F15-C1 … lists the following activities in the oil and gas context that are [excluded]: operating an oil or gas well or extracting petroleum or natural gas from a natural accumulation of petroleum or natural gas; processing natural gas as part of the business of selling or distributing gas in the course of operating a public utility; processing heavy crude oil recovered from a natural reservoir in Canada to a stage that is not beyond the crude oil stage or its equivalent; and “Canadian field processing” as defined in subsection 248(1). ...

. … However … where salary and wages are only reflected by journal entry as an expense by the employer with a corresponding credit to a due to shareholder loan account, such salary and wages are not considered eligible remuneration paid to an eligible employee for purposes of subsection 125.7(2). ...

In determining whether a taxpayer or a partnership has made or obtained records or documents that provide a description that is complete and accurate in all material respects of the items listed in subparagraphs 247(4)(a)(i) to (vi), the CRA will continue to rely on the guidance found in the … TPM-09 …. ...

. … Consequently … SENC could elect, under subsection 1103(1), to include in Class 1 of Schedule II, the properties in Classes 8 and 10, but could not include those covered by the election under subsection 1101(5b.1). ...