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. … Accordingly, the taxable dividend deemed to be received would need to be reported in the individual's final personal income tax and benefit return. ...

Amounts paid to the employee for such travel must therefore be included in computing the employee's income … [and] the employee cannot deduct personal travel expenses in computing income from an office or employment. ...

., a desk or chair) – but that the $500 limitation applies to all such equipment on a per employee basis so that, for example, where the employer reimburses the $400 and $250 cost of a desk and computer monitor, respectively, CRA will consider the $150 excess over $500 to be a taxable benefit. ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 6, 2020-0851631C6 F- Options d’achat d’actions- disposition au décès-- summary under Paragraph 7(1)(e) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(e) s. 110(1)(d.01) gift deduction is unavailable against a s. 7(1)(e) stock option benefit S. 110(1)(d.01) provides for an additional ½ deduction (so as to result in a nil taxable income inclusion) where the s. 110(1)(d) deduction was available for a s. 7(1)(a) stock option benefit and there is a timely gift of the optioned security to a qualified donee. ...

CRA, in its response, added: Furthermore … if it were the case that certain reorganizations or conversions of shares carried out through a transaction, or as part of a series of transactions, one of the main purposes of which is to enable shareholders to receive capital dividends, then the application of subsection 83(2.1) should be considered ...

. … Except in situations of indirect arrangements or loans referred to in subsection 17(2), section 17 generally does not apply to an amount that is owed to an individual. ...

Thus, to the extent that the applicable corporate law allows the corporation to pay a separate dividend on a series of shares of a given class of its capital stock … the election provided for in subsection 83(2) could be made with respect to the dividend that became payable on that series. ...

Without referring specifically to s. 16, CRA indicated that this position was contrary to Shell Canada, which found that absent a specific provision to the contrary or sham, the taxpayer’s legal relationships must be respected – so that withholding tax would not apply in such a situation absent a finding of sham or the application of a specific provision, e.g., s. 245 or 247. 5 September 2020 IFA Roundtable, Q.2 is similar. ...

Therefore, as the amount is calculated for an eligible employee in respect of a week in the qualifying period, it is our view that the qualifying entity has discretion to claim a lesser amount in its application by excluding any employees from the wage subsidy calculation under subsection 125.7(2) …. ...

. … [T]here are situations in respect of which our Directorate will not or cannot issue an advance income tax ruling (“ruling”). ...