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In other words, the settlement of a commercial debt that results in the application of section 80 automatically and immediately reduces the NCL balance for a taxation year because of the D.2 element of the NCL definition in subsection 111(8). ­­­­­­­­­­­­­­­­­­­­­­­ ...

. … Given that the employer acted on behalf of the employee by paying an invoice that otherwise would be borne by the employee, we are of the view that the amounts were constructively received by the employee. ...

As a result, the total amount of the allowances, as well as meal vouchers, should be included on the T4 slip in box 14 …. ...

1 March 2012 Internal T.I. 2012-0437901I7 F- Timing of the adjustments pursuant to 111(5)-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) acquisition of control of target does not reduce its NCLs at that time – streaming rules apply prospectively A corporation acquired all of the shares of a target corporation, resulting in an acquisition of control, and a day later, they amalgamated to form "Amalco". ...

. … [I]t appears to us, based in particular on the conflict of law rules, that the provincial and territorial laws of property and civil rights in Canada provide for mutual recognition of different types of entities or arrangements established under the respective jurisdictions of the various provinces and territories, thus providing an expanded base for analysis that is uniform across Canada for the purposes of applying the two-step approach. ...

. … Normally, an employee is not required to repay a salary advance as long as he or she continues to perform the services (i.e., remains employed). ...

28 April 2011 Internal T.I. 2011-0394301I7 F- Obligation de l'employeur- feuillet T4 modifié-- summary under Subsection 152(4.2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.2) procedure for employee to request correction of incorrectly reported T4 benefit When asked what an employer should do when it discovers that T4 slips issued by it incorrectly showed an automobile benefit, CRA stated: [S]ubsection 152(4.2) … covers, in particular, situations in which an employee, who has received T4 slips that have been amended for previous taxation years, requests the CRA to correct the income tax return already filed for those taxation years. ...

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. ...