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Regarding the deductibility of the pilot’s meal expenses, CRA stated: [O]ne of the conditions for claiming a deduction for meals under paragraph 8(1)(g) … is that an employee must generally be away from home overnight in the performance of their employment duties. ...

26 June 2020 External T.I. 2017-0688121E5 F- Déductibilité des intérêts et pénalités imposées sur les taxes foncières-- summary under Section 67.6 Summary Under Tax Topics- Income Tax Act- Section 67.6 tardiness “penalty” added by municipality to unpaid property taxes came within s. 67.6 After indicating that “interest charged on an unpaid balance of property taxes will be deductible if the property taxes themselves are deductible,” CRA indicated regarding a tardiness penalty of 0.5% per month of the unpaid taxes added by a municipality pursuant to s. 250.1 of the Act respecting municipal taxation ("AMT"): [S]ection 67.6 … prohibits the deduction in computing income of any penalty imposed under the laws of a country or a political subdivision thereof. ...

. … [T]his allowance is deemed not to be reasonable under subparagraph 6(1)(b)(x) because the use of the vehicle is not determined solely on the basis of the number of kilometres driven to perform the duties of the employment. ...

. … In its review, the Income Tax Rulings Directorate will have to consult internal stakeholders and the whole process may take some time. ...

. … Since a “branch” of a non-resident corporation is not a separate legal entity from the non-resident corporation, payments to a Canadian branch of a non-resident corporation made in respect of services provided in Canada are subject to Regulation 105 withholding.... ...

11 March 2024 External T.I. 2022-0939331E5- Workers’ Compensation Settlement-- summary under Paragraph 153(1)(a) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no withholding on WSIA worker’s compensation CRA noted that since s. 56(1)(v) requires an income inclusion for "compensation received under an employees’ or workers’ compensation law … of a province in respect of an injury,” compensation received by the estate of an injured worker pursuant to the Ontario Workplace Safety and Insurance Act was includible in its income (and deductible in computing its taxable income.) ...

CRA indicated that to the extent that the Government Assistance received by Aco was in respect of the acquisition of depreciable property (or land), s. 13(7.1) (or s. 53(2)(k)) will deem that amount to reduce the capital cost of the depreciable property (or land) – without any inclusion under s. 12(1)(x) pursuant to s.12(1)(x)(vi) and (in contrast with s. 13(7.4) or 53(2.1)) without any election required. ...

. … [A]ny change in the value of such an investment does not constitute an amount that was expended during the period in which the loss occurred. ...

However, in most cases, because of the nature of the expense, it may be difficult to completely separate the entertainment aspect from the strictly professional aspect of the event …. ...

15 February 2006 External T.I. 2005-0148311E5- Characterization of a French SNC-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation French société en nom collectif ("SNC") is a partnership In clarifying that it had not recently changed its view that a French société en nom collectif ("SNC") was a partnership rather than a corporation for ITA purposes, CRA stated: CRA … considers a French SNC that has its place of effective management in France for French tax purposes, to be a partnership for the purposes of the Act regardless of whether or not it has made an irrevocable election to be taxed as a corporation under French tax law. ...