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23 March 2005 Internal T.I. 2005-0113931I7 F- Safe income on hand calculation: Life Insurance-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) non-deductible life insurance premiums reduced SIOH Opco, whose shares had always been held by Holdco, acquired an interest in a life insurance policy (the Policy) to insure the life of a shareholder of Holdco, was the owner of the Policy and paid the premiums on the Policy, of which a portion was the savings component that was reflected during this period in the cash surrender value of the Policy. ... The Directorate stated: Opco must deduct in computing its safe income on hand attributable to the shares held by Holdco all amounts paid by it during the relevant calculation period as premiums under the Policy …. ... Based on the information you have provided to us, this amount is equal to … the ACB of the Policy. ...

1 April 2005 External T.I. 2004-0097171E5 F- Item gagné lors d'un tirage-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) prize won in raffle by employee was includible in employee’s income to the extent of the portion of its value that was funded by the employer rather than fellow employees Prior to the closure of a company division, the social club of that division decided to use up the funds in the club fund (to which the employer and employees had contributed equally) to purchase an item for more than $2,000, and make it the prize in a random draw among the employees. CRA stated: As indicated in … IT-213R, the amount or value of a prize received by a taxpayer from a lottery scheme is not taxable as either a capital gain or income unless … the prize can be considered, inter alia, to be income from employment. … [A]lthough the item was won by chance by an employee, it was received by the employee in the course of the employee’s employment since only employees could participate in the draw. ...

26 April 2005 External T.I. 2004-0107761E5 F- Aide à domicile/SAAQ-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit Maurice inapplicable where the adult, mentally capable, victim receives the insurance himself and pays it as compensation for his wife’s care services A taxpayer, injured in an automobile accident in 1994, received in 2004 a sum from the Quebec auto insurer (the “SAAQ”) to reimburse him for the amounts that he had paid to his wife for her personal care of him over the previous 10 years. ... The amount reimbursed to the taxpayer by the SAAQ, which his wife has certified as being receivable by her, is therefore to be included in computing the income of the person who rendered the services, i.e. the wife, as business income …. Where a victim receives the assistance amounts himself … and he freely choose to pay a family member instead of using the services of a third party, we are of the view that the amounts received by the service provider are taxable in service provider’s hands, even if the service provider is the victim's spouse, since those situations do not fall within the concept of support obligations raised in Maurice …., but rather reflect our general position. ...

13 July 2005 External T.I. 2005-0131351E5 F- Séparation des conjoints de fait-- summary under Paragraph 74.5(3)(a) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(3)- Paragraph 74.5(3)(a) attribution resumed when cohabitation resumed Common-law partners (Monsieur and Madame) had a child of their union, and then lived separate and apart starting on April 15, 2004 (with Monsieur then transferring a rental property to Madame), and then resumed cohabiting on November 1, 2004. CRA indicated that the income from the rental property will be attributed after their reconciliation to the transferor (Monsieur), stating: [T]hey ceased to cohabit on April 15, 2004 ("that time" in the definition of "common-law partner"), ending their common-law relationship on that date. … [I]n the absence of [s. 74.5(3)(a)], the income from the rental property attributable to the period between April 15, 2004 and November 1, 2004 would have been attributed to Monsieur. ... [I]f there had been a resumption of their common life within the 90-day period, there would never have been a break down in the common-law partnership and the attribution rules would still have applied during the period in question (from April 15, to November 1, 2004). … [T]he income from the rental property attributable to the period after November 1, 2004 will … be attributed to Monsieur. ...

24 January 2005 External T.I. 2004-0099471E5 F- Convention de retraite pour un actionnaire-employé-- summary under Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement a significant reduction in bonus or salary matched by an RCA contribution likely suggests it instead is an SDA After noting that contributions by a corporation to an RCA would not be deductible in computing its income where the contributions related to services rendered by a shareholder-employee while self-employed and before the corporation’s incorporation, or to the extent that s. 67 applied, CRA turned to the question whether there would be an SDA if the corporation regularly reduced bonuses to a shareholder-employee by the amount of related contributions to the employee RCA for its employees, and stated: Where a plan or arrangement can qualify as both an RCA and an SDA, it will be treated as an SDA …. … [I]t can be assumed that, except in special circumstances, where a portion of an employee's salary or wages is deferred under an agreement, one of the main purposes is to defer the payment of taxes. … [W]here a significant portion of the salary or bonus to which a shareholder-employee is entitled for services rendered is reduced so as to be contributed to an RCA instead, the existence of the RCA could be questioned since the contribution made by the employer may not relate to benefits that are receivable at retirement. ...

18 October 2005 Internal T.I. 2005-0133411I7 F- Penalty for repeated failures to report income-- summary under Subsection 163(1) Summary Under Tax Topics- Income Tax Act- Section 163- Subsection 163(1) simultaneous filing of returns for three successive years, each with unreported income, did not engage s. 163(1) (if no unreported income in prior years) Mr. ... Regarding the first assumption, CRA stated: [T]he better position is that [s. 163(1)] does not apply where a taxpayer files T1 income tax returns simultaneously for a number of consecutive taxation years and the taxpayer's income tax returns for the earlier taxation years were filed in accordance with the provisions of the Act …. … [T]he CRA should not apply subsection 163(1) respecting Mr. Y's unreported income under the first scenario …. Regarding the second assumption, CRA stated: [I]f the failure to report an amount to be included in Mr. ...

11 October 2005 External T.I. 2005-0148281E5 F- Déductibilité de dépenses-- summary under Legal and other Professional Fees Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Legal and other Professional Fees accounting fees in preparing consolidated financial statements generally deductible In finding that accounting fees related to the preparation by a parent of consolidated financial statements for the group were generally deductible, CRA stated: … IT-99R5 … lists legal and accounting fees for a wide range of ordinary functions. ...

11 October 2005 External T.I. 2005-0148281E5 F- Déductibilité de dépenses-- summary under Subsection 248(24) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(24) s. 248(24) does not affect deductibility of fees for preparing consolidated financials In finding that accounting fees related to the preparation by a parent of consolidated financial statements for the group were generally deductible, CRA stated: … IT-99R5 … lists legal and accounting fees for a wide range of ordinary functions. ...