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Technical Interpretation - External

11 January 2019 External T.I. 2018-0740741E5 - Taxation of supplemental retirement plans

The bonus contribution and vacation pay contribution components as well as the Retirement Allowance Plan appear to be primarily motivated by tax deferral considerations and would likely constitute an SDA. ... However, the bonus contribution and vacation pay contribution components of the Supplemental Plan, as well as the Retirement Allowance Plan, appear to be primarily motivated by tax deferral considerations. ...
Technical Interpretation - External

13 February 2020 External T.I. 2019-0825501E5 - Donation of shares

Subsection 248(30) of the Act is a relieving provision that generally states that the receipt of a benefit or consideration (advantage) will not, in and of itself, disqualify a transfer of property from being a gift to a qualified donee for income tax purposes. In general terms, an advantage is the total value of any property, service, compensation, use or any other benefit that a donor (or a person or partnership not dealing at arm’s length with the donor) is entitled to as partial consideration for, in gratitude for, or in any other way related to the gift. ...
Technical Interpretation - External

19 June 1991 External T.I. 9111545 F - Deferred Salary Leave Plan

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the Trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...
Technical Interpretation - External

19 November 1991 External T.I. 9120435 F - Salary Deferral Arrangement Plan

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee. ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

11 April 1990 External T.I. 58705 F - Tax Treatment of Bond Premium

.), the full amount of the premiums have the quality of income when received and therefore are included in income of the issuer under section 9 of the Act, as the premiums represent consideration for the issuance of the obligations and are received regardless of the period of time that the debt is outstanding.  ... Thus the prime consideration, where there is a dispute about a system of accounting, is, in the first place, whether it is appropriate to the business to which it is applied and tells the truth about the taxpayer s income position and, if that condition is satisfied, whether there is any prohibition in the governing income tax law against its use.  ...
Technical Interpretation - External

3 September 1991 External T.I. 9117755 F - Deferred Salary Leave Plan

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...
Technical Interpretation - External

1 May 1991 External T.I. 9100525 F - Deferred Salary Leave Plan

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the Trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year. ...
Technical Interpretation - External

9 May 1991 External T.I. 9108405 F - Deferred Salary Leave Plan

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the Trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...
Technical Interpretation - External

27 November 1991 External T.I. 9121855 F - Deferred Salary Leave Plan

Consequently, while CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of  contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...
Technical Interpretation - External

11 March 1992 External T.I. 9205405 F - Deferred Salary Leave Plan-Teacher's One-Semester Leave

Consequently, although CPP contributions that are required to be paid during the leave period are to be deducted and remitted by the trustee as by any other employer, CPP contributions paid in the year prior to the leave period must be taken into consideration by the trustee.  ... However, since CPP contributions made during the year prior to the leave period are to be taken into consideration by the trustee, the amount of contributory earnings reported by the trustee may not coincide with the earnings reported in box "C" for that particular year.  ...

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