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S1-F2-C3 - Scholarships, Research Grants and Other Education Assistance

In both cases, the deduction applies only to tuition assistance and not to other types of assistance a student may receive in connection with the student’s training. ... The deduction can also apply to tuition assistance received in connection with basic adult education. ... An award will be considered to be received in connection with the taxpayer’s enrolment in an educational program where it satisfies the conditions outlined in paragraph 56(3.1)(a) (see ¶ 3.96). ...
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S1-F3-C4 - Moving Expenses

Whether such a connection exists in a given situation can only be determined by examining the circumstances surrounding the move. 4.8 The required connection does not exist when an individual moves solely for personal reasons. 4.9 For an employee or self-employed individual, the connection can exist, for example, in the following situations: an employee moves due to a transfer to another establishment of the employer; or a self-employed individual moves for business reasons, such as needing to be closer to a possible market or resources needed for the business (for example natural resources, raw materials, or specialized equipment). Generally, the connection can exist even if there is a delay between the move and the time the business or employment activity at the new work location is undertaken. 4.10 For a student, the connection may exist and an eligible relocation may occur even if a student moves to attend an educational institution as well as to be employed. ... Utilities can include telecommunication services, such as cable, satellite television, and Internet connection. ...
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S4-F2-C1 - Deductibility of Fines and Penalties

If a fine or penalty is incurred in connection with the acquisition or production of inventory, the fine or penalty is included in the cost of inventory. 1.21 If a fine or penalty is incurred before January 1, 2017, in connection with the acquisition of an eligible capital property, the fine or penalty is an eligible capital expenditure provided all the other tests in the former subsection 14(5) definition of eligible capital expenditure are met. ... After 2016, the amounts incurred are generally considered depreciable property included in Class 14.1, as described in ¶1.20. 1.22 If a fine or penalty (such as a penalty paid on the prepayment of a mortgage or hypothec) is incurred in connection with the disposition of a capital property, the fine or penalty is taken into account under subsection 40(1) for purposes of calculating any gain or loss on that disposition. ... However, exceptions to this rule may apply where: a prepayment penalty is incurred in connection with the disposition of a capital property (see ¶1.22.); a prepayment penalty qualifies as an eligible moving expense for purposes of subsection 62(3) (for more information, see Income Tax Folio S1-F3-C4, Moving Expenses); or a prepayment penalty qualifies as a current expense for the particular business, e.g., the business of trading in mortgages. ...
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S4-F8-C1 - Business Investment Losses

The burden of demonstrating a sufficient connection between the taxpayer’s loan to (or the taxpayer’s guarantee of the debts of) the debtor and the potential for income will be much higher in situations where the taxpayer is not a direct shareholder of the debtor. ... For an example of a case where the connection was found to be too remote, see Service v The Queen, 2004 TCC 592, 2004 DTC 3317, which was affirmed by the Federal Court of Appeal in Service v Canada 2005 FCA 163, 2005 DTC 5281). ... Therefore, in connection with the disposition of the debt, Mr. R’s 2015 tax return will also reflect an allowable capital loss in the amount of $60,000 ($120,000 x ½). 1.65 The reduction under subparagraph 39(1)(c)(viii) in the case of a disposition by a trust of a share or a debt in an SBC is the amount determined under subsection 39(10). ...
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S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs

Definition of advantage 3.5 An advantage in relation to a registered plan is defined in subsection 207.01(1) as any of the following: certain benefits or debt that are conditional on the existence of the plan, subject to listed exceptions (see ¶3.6 to 3.15) an increase in the FMV of the property held in connection with the plan which increase is reasonably attributable to certain transactions or amounts (see ¶ 3.16 to 3.26) income or a capital gain that is reasonably attributable to certain property or transactions in respect of the plan (see ¶ 3.28 to 3.31) a registered plan strip in respect of the plan (see ¶ 3.32 to 3.34) Conditional on plan 3.6 Paragraph (a) of the definition of advantage includes any benefit, loan or indebtedness that is conditional in any way on the existence of the registered plan, subject to certain enumerated exceptions discussed in ¶3.7 to 3.12. ... That is, the advantage tax will nonetheless apply in respect of any future increases in the total FMV of the property held in connection with the plan that are reasonably attributable, directly or indirectly, to the swap transaction. ... Settlement payments 3.42.1 Occasionally, payments may be made to settle a class-action lawsuit or other legal proceeding in respect of actionable losses incurred in connection with assets of registered plans. ...
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S4-F3-C2 - Provincial Income Allocation

Amounts excluded from gross revenue 2.23 Subsection 402(5) of the Regulations provides that for purposes of subsection 402(3), gross revenue of a corporation does not include interest on bonds, debentures or mortgages, dividends on shares of capital stock, or rentals or royalties from property that is not used in connection with the principal business operations. 2.24 In Provincial Income Allocation Newsletter No. 1 the CRA confirmed that a broad interpretation of the excluded amounts is appropriate for the purposes of Part IV of the Regulations. Under such a broad interpretation, interest on promissory and other notes, bankers’ acceptances, intercompany loans, certificates, guaranteed investment certificates, and any unsecured debt instruments or other similar obligations would also be excluded from the gross revenue of a corporation. 2.25 In addition, the reference in subsection 402(5) to “that is not used in connection with the principal business operations of the corporation” refers only to “rentals or royalties from property” and not to the other items enumerated in that subsection. 2.26 Examples of amounts that would normally be excluded in determining gross revenue of a corporation for purposes of Part IV of the Regulations include the following: Amounts received or receivable in respect of expenditures incurred by the corporation. ... Other factors that are relevant in determining whether an individual is an employee of a permanent establishment of any particular province include the following: whether the individual is also considered to be an employee of that establishment for provincial government related filing requirements (for example, income tax deduction, medical premium deduction, etc.); whether the employee maintains an office or other connections in that establishment; and whether the employee normally reports to or receives instructions from that establishment. 2.61 Under paragraph 413(1)(a) of the Regulations, where a corporation is not resident in Canada, “salaries and wages paid in a year” does not include salaries and wages paid to employees of a permanent establishment outside Canada. ...
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S1-F3-C2 - Principal Residence

X lived in the residence from October 15, 2007 until he disposed of the property on December 1, 2011 for $250,000, incurring no costs in connection with the disposition. ... Form T2062, Request by a Non-Resident of Canada for a Certificate of Compliance Related to the Disposition of Taxable Canadian Property, or a similar notification, must be filed in connection with a request for a section 116 certificate. ... It has been assumed in these examples that, on each actual disposition, no costs were incurred in connection with that disposition. ...
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S1-F1-C3 - Disability Supports Deduction

Where the taxpayer has a perceptual disability, the cost of talking textbooks used by the taxpayer in connection with the taxpayer's enrolment at a secondary school in Canada or at a designated educational institution is an eligible expense, provided that a medical practitioner has certified in writing, that the taxpayer is a person who, because of that disability, requires those textbooks. ... This requirement remains if the attendant is resident in Canada for tax purposes. 3.10 Therefore, if a taxpayer who is resident in Canada for tax purposes has a perceptual disability and incurs the cost of a talking textbook used in connection with the taxpayer’s enrolment at a secondary school located outside of Canada or, if the taxpayer is a person with a disability who incurs the cost of attendant care provided outside Canada, the costs incurred will be eligible for the disability supports deduction assuming all the other requirements of section 64 (as discussed in ¶ 3.1 to 3.8) are met. ...
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S2-F1-C2 - Retiring Allowances

In this context, the words in respect of have been held by the courts to imply a connection between the loss of employment and the subsequent receipt, where the primary purpose of the payment is to compensate for the loss of employment. Two questions set out by the courts to determine whether such a connection exists for purposes of a retiring allowance are as follows: Question 1 – But for the loss of employment would the amount have been received? ...
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S4-F2-C2 - Business Use of Home Expenses

Personal or living expenses 2.34 Expenses relating to an individual’s home that are personal or living expenses are specifically precluded from deduction by paragraph 18(1)(h). 2.35 The term personal or living expenses is defined in subsection 248(1) to include: “… the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or common-law partnership or adoption, and not maintained in connection with a business carried on for profit or with a reasonable expectation of profit.” 2.36 Generally, an expense is incurred in connection with a business if there is a business purpose or need for the expenditure. ...

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