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Technical Interpretation - Internal summary

22 August 2017 Internal T.I. 2017-0688301I7 - Restrictive Covenant -- summary under Paragraph 56.4(3)(c)

22 August 2017 Internal T.I. 2017-0688301I7- Restrictive Covenant-- summary under Paragraph 56.4(3)(c) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(3)- Paragraph 56.4(3)(c) agreement not to solicit employees not assimilated When presented with an agreement for the sale of the shares of a private company under which various shareholders were required to agree to a non-competition covenant (“NCC”) and a non-solicitation covenant (“NSC”), the Directorate found that “essentially, the terms of the NCC and NSC reflect the conditions that one might normally expect to see in a typical non-competition agreement,” so that they “could be treated as a single RC [restrictive covenant] that is in respect of a non-compete covenant.” ... Before so concluding, the Directorate noted that, in dealing with the similar language in s. 56.4(3)(c)(ii), it had considered that s. 56.4(3)(c)(ii) would allow an election with respect to the undertaking not to solicit the clients of the corporation that is sold, but it would not allow such an election with respect to the value of an undertaking not to solicit the employees to change employment... and that the fact that a non-competition agreement may include both a non-competition and a confidentiality clause would not in and of itself disqualify the entire non-competition agreement for the purposes of the exceptions in subsection 56.4(3) or 56.4(7). ...
Technical Interpretation - Internal summary

27 October 2017 Internal T.I. 2017-0694231I7 - Subsection 247(2), surplus, and FAPI -- summary under Subsection 5907(2)

The Directorate went on to state: The surplus of CFA could conceivably be adjusted where CFA’s “earnings” are computed pursuant to subparagraph (a)(i) or (a)(ii) of the definition of “earnings” under [Reg.] 5907(1) and the relevant foreign tax law makes its own transfer pricing adjustment, whether by way of a corresponding adjustment or otherwise. …[C]onsideration would have to be given to whether subsection 5907(2) could reverse that foreign tax law adjustment and to the possible impact of any accompanying transfer of assets to effect a so-called “repatriation” payment. ...
Technical Interpretation - Internal summary

16 August 2017 Internal T.I. 2017-0701291I7 - Exclusive Distributorship Rights -- summary under Article 12

However, turning to the Treaty, the Directorate stated: To the extent the Upfront Payment is subject to Part XIII tax under subparagraphs 212(1)(d)(i), 212(1)(d)(iv) or paragraph 212(1)(i), the Upfront Payment should be exempt from Canadian withholding tax under Article VII …. A substantially similar definition of the term “royalties” [to that in the Treaty] is found in Article 12 of the Model Convention …. ...
Technical Interpretation - Internal summary

9 April 2018 Internal T.I. 2017-0731251I7 F - Activités mondaines -- summary under Paragraph 6(1)(a)

. If the cost of the party is greater than $150 per person, the entire amount, including the additional costs, is a taxable benefit.” CRA then stated: [T]he "per person" cost of $150 for this position is based on the total number of people attending the party or social event. [A] person who is invited to a party or a social event but who does not attend has not received or enjoyed a benefit. ...
Technical Interpretation - Internal summary

30 May 2003 Internal T.I. 2003-0000117 F - ALLOCATION AUTOMOBLE VERSÉE -- summary under Subparagraph 53(2)(c)(v)

From the perspective of the partner receiving such an allowance, it constitutes a distribution that reduces the adjusted cost base (ACB) of the partner's interest in the partnership pursuant to subparagraph 53(2)(c)(v) …. ... For the partner, this payment will be treated as a distribution and an adjustment to the ACB will be required pursuant to subparagraph 53(2)(c)(v) …. ...
Technical Interpretation - Internal summary

31 October 2003 Internal T.I. 2003-0040997 F - CHANTIER PARTICULIER REPAS CONJOINT -- summary under Paragraph 6(6)(a)

If the weekly allowance was to compensate the employee for actual expenses for "board and lodging" at the special work site, we are of the view that the amounts would be considered reasonable …. ...
Technical Interpretation - Internal summary

24 June 2004 Internal T.I. 2004-0065301I7 F - Frais médicaux - purificateur d'air -- summary under Paragraph 5700(c.1)

24 June 2004 Internal T.I. 2004-0065301I7 F- Frais médicaux- purificateur d'air-- summary under Paragraph 5700(c.1) Summary Under Tax Topics- Income Tax Regulations- Regulation 5700- Section 5700- Paragraph 5700(c.1) air exchanger can also serve as air purifier/ “severe” excludes seasonal allergies Regarding the eligibility of the cost including installation of an air exchanger that also functions as an air purifier and that operates only with a Hepa filter, CRA stated: [T]he fact that a piece of equipment has the dual function of being an air exchanger as well as an air purifier would not automatically exclude it from paragraph 5700(c.1) …. However, if an air exchanger and an air purifier are two separate devices that could be purchased separately only the cost of the air purifier could be allowable Regarding the meaning of "severe chronic respiratory ailment," CRA noted the following statement on the Health Canada website: There is no universal definition for chronic respiratory diseases. ...
Technical Interpretation - Internal summary

15 July 2004 Internal T.I. 2004-0071101I7 F - Site de neiges usées -- summary under Paragraph (e)

After finding that the storage tank did not fall within Class 8(c) as the Directorate did “not believe that the settling tank is a building and that it was acquired for the purpose of "manufacturing or processing" as decantation is not a physical or chemical change produced by a technique of preparation or handling but rather a change resulting from a natural process,” the Directorate went on to find that it qualified under Class 6(e), stating: [T[he settling tank is a water storage tank …. ...
Technical Interpretation - Internal summary

10 May 2001 Internal T.I. 2001-0065737 F - ÉCHANGE DE BIEN - 13(4) -- summary under Paragraph 13(4)(d)

It then stated: Consequently, the replacement property (passenger vehicle) will have to be placed in a separate class 10.1 under [Reg.] 1101(af) and the reduction calculated under paragraph 13(4)(d) will be made to that class. No change of class may be made given the wording of [Reg.] 1103(2d) …. ...
Technical Interpretation - Internal summary

2 May 2002 Internal T.I. 2002-0122607 F - BIENS A USAGE PERSONNEL -- summary under Regulation 1102(2)

In finding that this does not signify that he has realized a $25,000 gain on the land, and a $10,000 loss on the building which is denied by s. 40(2)(g)(iii), the Directorate stated: Where a building constitutes depreciable property [Reg. 1102(2)] has the effect of splitting the property into two for the purposes of the Act, namely the land and the building. In the case of a cottage that is a PUP, we are of the view that the land and the building will remain one and the same property for tax purposes if they constitute one and the same property for legal purposes. [Here] the taxpayer will realize a capital gain of $15,000 on the disposition of his property. ...

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