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Indeed, the exception in subparagraph 6(1)(b)(vii) is intended to exclude allowances to compensate an employee for expenses incurred in connection with, and not as a result of, travel. ...

In rejecting a submission that this allowance should be construed as bifurcated into two allowances, one of which was reasonable as required by s. 6(1)(b)(x), CRA stated: [I]n determining the reasonableness of a travel allowance, the phrase "solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment” (emphasis added) in subparagraph 6(1)(b)(x) refers to the use of the vehicle for business purposes only. ...

21 March 2006 External T.I. 2005-0158451E5 F- Québec Mining Duties Act- Credit for Losses-- summary under Paragraph 12(1)(x.2) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x.2) credit under the Quebec Mining Duties Act based on exploration and development losses of operator was not includible under s. 12(1)(x.2) S. 32 of the Quebec Mining Duties Act (MDA) provided a credit to an operator equal generally to an amount not exceeding 12% of the lesser of (i) its annual loss (excluding the portion thereof attributable to ore processing activities) and (ii) the amount by which the expenses in respect of exploration, mineral deposit evaluation and mine development work, incurred by the operator for the fiscal period in connection with the mining operation, exceeds the amount of government assistance that the operator received or was entitled to receive relating to those expenses. ...

21 March 2006 External T.I. 2005-0158451E5 F- Québec Mining Duties Act- Credit for Losses-- summary under Paragraph 66(12.6)(a) Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(12.6)- Paragraph 66(12.6)(a) credit under the Quebec Mining Duties Act based on exploration and development losses of operator was too remote from the exploration to reduce the renounced CEE S. 32 of the Quebec Mining Duties Act (MDA) provided a credit to an operator equal generally to an amount not exceeding 12% of the lesser of (i) its annual loss (excluding the portion thereof attributable to ore processing activities) and (ii) the amount by which the expenses in respect of exploration, mineral deposit evaluation and mine development work, incurred by the operator for the fiscal period in connection with the mining operation, exceeds the amount of government assistance that the operator received or was entitled to receive relating to those expenses. ...

In connection with agreeing that the alter ego trust is entitled to a deduction under s. 104(6)(b) for the amount of dividend income received by it that was made payable to the primary beneficiary prior to the death, CRA discussed the effect of B in the formula limiting the deductible amount as follows: [E]lement B of the formula restricts the deduction available to the trust as follows: for the trust’s year in which the primary beneficiary dies and prior years, clause (i)(A) of the description of element B ensures that no deduction may be made by the trust for income which became payable to a beneficiary other than the primary beneficiary, and for the trust’s year in which the primary beneficiary dies, subclause (i)(B)(I) ensures that no deduction is available to the trust in respect of any amount included in the trust’s income because of the application of subsections 104(4) to (5.2) (the “deemed disposition rules”) or subsection 12(10.2) of the Act. ...

Since no amount was paid in connection with the cancellation of these shares, the application of subsection 84(3) would not cause Opco to be deemed to have paid a dividend on a separate class of shares at the particular time. ...

Art. 12 of the Canada-U.K Treaty exempted copyright royalties, but there was an exclusion from this exemption for payments in respect of motion pictures or of works on film, videotape or other means of reproduction for use in connection with television broadcasting. ...

23 March 2004 External T.I. 2003-0049031E5 F- Paragraphe 15(2) de la Loi et "montant remis"-- summary under Excluded Obligation Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1)- Excluded Obligation loan included in income under s. 15(2) was excluded obligation re its subsequent forgiveness In connection with finding that if an interest-free loan to the adult child of Opco’s sole shareholder in in 2003 was to be included in the child’s income pursuant to s. 15(2), the subsequent forgiveness of the loan in 2006 did not result income under s. 15(1.2), CRA stated: The expression "forgiven amount" in subsection 15(1.21) refers, inter alia, to the meaning that would be given to that expression by subsection 80(1), which indicates, inter alia, that the lesser of the principal amount of the debt or the amount for which the debt was issued is reduced by the portion of the principal amount of an excluded obligation. ...

CRA then stated: Assuming that the expenses [instead] are incurred in connection with a convention held during a sea cruise, it is our view that no amount for expenses incurred to attend the convention would be deductible since the convention would be held outside the geographical boundaries of the association that is the sponsor of the convention, as discussed in paragraph 2 of IT-131R2. ...

(e) effectively requires a combined 24-month holding period for s. 110.6(14)(f)(i) or (iii) transactions In connection with indicating that, where an individual shortly after commencing a proprietorship, transfers all of the assets used such active business to a newly-incorporated corporation in exchange for treasury shares of the corporation, the individual can benefit from the s. 110.6(2.1) deduction even if the individual disposes of those shares within 24-months of having commenced the proprietorship, CRA stated: [T[here is no mechanism in [the s. 110.6(14)(f)(ii)] relief rule that combines the period during which the business was operated as a sole proprietor with the period during which the shares of the corporation were held to ensure that this period is at least 24 months. ...