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Technical Interpretation - External

16 March 2000 External T.I. 2000-0004945 - STANDBY CHARGE-LIMITED USE OF VEH.

You agree with being charged a prescribed amount per kilometre for operating costs in connection with personal use. ... This value is an amount equal to a prescribed amount per kilometre for operating costs in connection with personal use and a "reasonable standby charge" (plus the equivalent to the Goods and Services Tax (GST) on the standby charge). ...
Technical Interpretation - External

21 March 2000 External T.I. 2000-0004965 - STANDBY CHARGE-RESTRICTED USE OF VECH.

You agree with being charged a prescribed amount per kilometre for operating costs in connection with personal use. ... This value is an amount equal to a prescribed amount per kilometre for operating costs in connection with personal use and a "reasonable standby charge" (plus the equivalent to the Goods and Services Tax (GST) on the standby charge). ...
Technical Interpretation - External

16 March 2000 External T.I. 2000-0004975 - STANDBY CHARGE-RESTRICTED USE OF VEH.

You agree with being charged a prescribed amount per kilometre for operating costs in connection with personal use. ... This value is an amount equal to a prescribed amount per kilometre for operating costs in connection with personal use and a "reasonable standby charge" (plus the equivalent to the Goods and Services Tax (GST) on the standby charge). ...
Technical Interpretation - External

10 April 2000 External T.I. 2000-0005305 - PERSONAL SERVICE CORPORATIONS

Your concerns relate to individuals who operate equipment, drive trucks, or provide their labour in connection with the resource industry. ... In connection with a personal services business, we note that employment is not insurable and is not subject to EI premiums when a corporation employs a person who controls more than 40% of the corporation's voting shares (see enclosed page 21 of the "Employer Guide to Payroll Deductions"). ...
Technical Interpretation - External

10 April 2000 External T.I. 2000-0013085 - REASONABLENESS OF MANAGER BONUS

In our answer to question 42 we stated that, in general, we will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders-managers of a corporation when: a) the general practice of the corporation is to distribute the profits of the company to its shareholders-managers in the form of bonuses or additional salaries; or b) the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of the shareholders. ... In our answer to question 42 at the 1981 CTF, we stated that, in general, we will not challenge the reasonableness of salaries and bonuses paid to the principal shareholders-managers of a corporation when: a) the general practice of the corporation is to distribute the profits of the company to its shareholders-managers in the form of bonuses or additional salaries; or b) the company has adopted a policy of declaring bonuses to the shareholders to remunerate them for the profits the company has earned that are, in fact, attributable to the special know-how, connections, or entrepreneurial skills of the shareholders. ...
Technical Interpretation - External

30 May 2000 External T.I. 1999-0009785 - Section 122.3 vacation

Vacation will generally not impact the issue of whether the individual would be considered to have "performed substantially all of the duties of the individual's employment outside Canada in connection with a contract" for the purposes of the test in paragraph 122.3(1)(b) of the Act. ... Therefore, it is our opinion that the measure of the "all or substantially" test is based on a comparison of the time actually worked outside Canada in connection with the contract for the individual's employer during the qualifying period as compared to the total time the individual actually worked (i.e. excluding vacation time off) in that same period. ...
Technical Interpretation - External

14 September 2000 External T.I. 2000-0033275 - CONVERT PRINCIPAL RESIDENCE TO BUS. USE

Interpretation Bulletins provided on component parts and equipment and service connection. ... Paragraph 20(1)(ee) of the Act provides for a deduction from income from a business for a service connection, however, certain conditions must be met and those are stated in Interpretation Bulletin IT-452. ...
Technical Interpretation - External

10 August 1999 External T.I. 9919385 - NORTHERN RESIDENTS DEDUCTION

For the purposes of paragraph 110.7(l)(a) of the Act, it is the Department's position that there must be a connection between the actual travel expenses incurred by the taxpayer or a member of the taxpayer's household and the amounts paid by the taxpayer's employer to defray those costs. Since an employee generally can only receive a deduction under paragraph 110.7(l)(a) of the Act if, among other criteria, actual travel costs have been incurred by the employee or a member of his household (see clause 110.7(1)(a)(i)(A) of the Act and paragraph 7304(4)(b) of the Regulations), we are of the view that a reasonable agreed "per hour amount" or "annual premium" specified in an employment contract paid as an advance towards the trips (whether there is a requirement or not to take those trips) is a reasonable manner of providing travel assistance for employees residing in a prescribed zone and would generally constitute a sufficient "connection", as discussed above, to enable the employee to be eligible for the paragraph 11O.7(1)(a) deduction. ...
Technical Interpretation - External

3 July 2019 External T.I. 2018-0781941E5 - Foreign retirement plans (Ireland)

Pietrow 2018-078194 July 03, 2019 Dear XXXXXXXXXX: RE: Irish retirement plans We are writing in response to your email of October 6, 2018, in which you sought our views in connection with the Canadian income tax treatment of Irish retirement plans. ... To the extent a taxpayer would be subject to tax in Ireland in connection with the plan, a foreign tax credit may be available. ...
Technical Interpretation - External

9 August 2019 External T.I. 2019-0813021E5 - TOSI and excluded shares

Each of the Partnercos do not earn income other than the business income that arises in connection with their ownership in Partnership AB. 4. ... By virtue of clause 120.4(1.1)(d)(i)(B), the income of the Partnercos that arises in connection with the ownership of the Partnerco’s interests in Partnership AB will be considered to be derived directly or indirectly from the business of Partnership AB. ...

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