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22 February 2012 External T.I. 2011-0421671E5 F- Loss of retirement income benefit- death-- summary under Subparagraph 110(1)(f)(ii) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(f)- Subparagraph 110(1)(f)(ii) deduction for WSIB compensation paid to estate of deceased injured worker An injured worker was entitled to receive monthly payments from the Ontario Workplace Safety and Insurance Board ("WSIB") until 65, with a lump sum paid to the worker at 65 as compensation for the loss of the monthly payments – or to the worker’s survivors if he did not attain that age. ...

After describing the application of s. 70(5.1) to the original bequest, and noting that its policy on price adjustment clauses did not apply in this situation, CRA stated: [I]f it were appropriate to retroactively adjust the sale price, the CRA could apply subsection 152(4.2) in respect of taxation years already assessed … [but the] taxpayer must satisfy the five conditions for the CRA to agree to a reassessment giving rise to a refund. ...

. … [G]iven that the property would be the patrimony of an inter vivos trust, the transfer of the shares of a joint spousal or common-law partner trust will contaminate a future testamentary trust to be put in place on the death of Mr X or Ms X. ...

The Directorate first quoted a statement in 2005-0158871E5 that: [A] "representation allowance" in the context of subparagraph 6(1)(b)(iii) … is an allowance paid to a worker having to work outside the country and is intended to lessen the inconveniences arising out of having to move abroad, being subject to different living conditions and, where applicable, having to face a higher cost of living. ...

It then started leasing the property to a non-associated corporation – and then disposed of the property, thereby realizing recapture of depreciation. ...

We continue to believe that the term "person … connected with a shareholder of a particular corporation" as provided in subsection 15(2.1) may include a partnership. ...

In the course of a general discussion, CRA stated: Subsection 227(6.1) … provides for repayment of Part XIII tax paid on a loan deemed to be a dividend by virtue of paragraph 214(3)(a) if the borrower, in whose name the tax was paid, repays the loan after December 21, 1992 and the repayment was not made as part of a series of loans or other transactions and repayments. ...

. … [P]repaid expenses or expenses that are paid before they are actually incurred are not deductible in computing a taxpayer's income. ...

Where … an amount on which an income tax is payable under Part XIII was paid to an agent for or on behalf of the non-resident person who is entitled to payment without the tax having been deducted or withheld, subsection 215(3) provides that it is then the responsibility of the agent to deduct or withhold the Part XIII tax payable in respect of the amount received on behalf of the non-resident. ...

2 September 2011 Internal T.I. 2011-0419111I7 F- Programme de compensation du MESS-- summary under Paragraph 56(1)(u) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(u) social assistance payments aggregating less than $500 not required to be included in income After noting that payments made by Ministère de l'Emploi et de la Solidarité sociale (the "MESS") to individuals, who were homeless and receiving financial assistance of last-resort represented social assistance payments described in s. 56(1)(u), CRA stated: ITR subsection 233(2) provides that a T5007 return does not have to be filed in certain circumstances, including where: the payment is paid as a part of a series of payments, the total of which in the particular year does not exceed $500 …. ...