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9 July 2015 External T.I. 2013-0475421E5 - Section 94.2 -- summary under Section 233.5

CRA went on to state: … [A] failure to report income as required, and false statements or omissions, in respect of prescribed reporting requirements may result in substantial penalties under section 162 or 163. ...

16 April 2014 External T.I. 2013-0514521E5 - Employer-paid Personal Trainer and Nutritionist -- summary under Paragraph 6(1)(a)

. … Where counselling services are part of a program provided by a personal trainer or nutritionist, it is our view that the value of any benefit derived from such services would be difficult to separate from the value of any other benefits received or enjoyed under the program. ...

18 September 2013 External T.I. 2012-0462061E5 F - Amount included in the income of the annuitant -- summary under Subsection 146(8.3)

As a result … provided the amounts withdrawn are from an RRSP where only the annuitant paid premiums, the withdrawals would be included in the computation of the annuitant's income under subsection 146(8). ...

26 September 2014 External T.I. 2014-0531441E5 - Unfunded LTD plan payment to non-resident employee -- summary under Paragraph 115(2)(c)

. … As such, the amount of LTD Plan payments that would be taxable as income earned by a non-resident employee would be determined in accordance with subsection 115(2) and withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...

26 September 2014 External T.I. 2014-0531441E5 - Unfunded LTD plan payment to non-resident employee -- summary under Paragraph 153(1)(a)

. … As such, the amount of LTD Plan payments that would be taxable as income earned by a non-resident employee would be determined in accordance with subsection 115(2) and withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...

26 September 2014 External T.I. 2014-0531441E5 - Unfunded LTD plan payment to non-resident employee -- summary under Article 18

. … As such… withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...

7 October 2013 External T.I. 2013-0500941E5 F - Actif utilisé dans une entreprise active -- summary under Qualified Small Business Corporation Share

Before responding negatively, CRA stated (TaxInterpretations translation): … In this situation, 17% of the building is used in an active business carried on by XXXXXXXXXX. ...

14 March 2013 External T.I. 2012-0472361E5 F - Fournitures/outils - guides de pêche -- summary under Subparagraph 8(1)(i)(iii)

. … In order to determine whether an expense incurred by an employee, which was not expressly provided for in an employment contract, is in fact an implicit requirement of an office or employment, the courts have considered whether the fact of failure to comply could result in termination of employment, poor evaluation of employee performance or other disciplinary action by the employer. ...

14 March 2013 External T.I. 2012-0472361E5 F - Fournitures/outils - guides de pêche -- summary under Paragraph 8(1)(s)

. … [I]t appears that the property described in your letter is not tools. ...

2 April 2014 External T.I. 2014-0521041E5 F - Application de 13(7.1) -- summary under Subsection 13(7.4)

Before concluding that “subsection 13(7.1) should apply … so that an election under subsection 13(7.4) would not be required,” CRA noted: In a situation where subsection 13(7.1) does not apply, the election under subsection 13(7.4) can be made in order that the capital cost to the taxpayer of the property is reduced by the amount of government assistance received. ...

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