Search - considered

However, where the business of the partnership can be considered to be investing … the connecting factors set out in Recalma v. ...

28 August 2006 Internal T.I. 2006-0171141I7 F- Régime d'assurance collective contre la maladie-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) a qualifying plan can be implemented by individual disability insurance policies taken out for all management employees if there is a similar premium sharing arrangement for all Could the employer premiums paid for individual disability insurance policies taken out in respect of all the management employees be considered to be premiums paid respecting a group sickness or accident insurance plan? ...

13 September 2006 External T.I. 2006-0185161E5 F- Crédit d'impôt pour frais de scolarité-- summary under Paragraph 118.5(3)(d) Summary Under Tax Topics- Income Tax Act- Section 118.5- Subsection 118.5(3)- Paragraph 118.5(3)(d) fee for credit recognition of work placement might qualify Regarding fees paid by a student to a university to recognize theoretical and practical knowledge acquired through work experience and for which the university grants course credits under its post-secondary program, CRA stated: [T]he fees you described above may be considered ancillary fees that are paid on account of registration subject to the application of paragraph 118.5(3)(d). ...

14 September 2006 External T.I. 2006-0167861E5 F- Frais de représentation-- summary under Paragraph 67.1(2)(a) Summary Under Tax Topics- Income Tax Act- Section 67.1- Subsection 67.1(2)- Paragraph 67.1(2)(a) taxpayer is not considered to receive compensation for restaurant bills where they are included in its estimates but not explicitly in its invoices A marketing and communication agency (the "Corporation"), as part of its engagements for raising awareness of client products, incurs restaurant bills, which it included in its fee quotations to the clients, but for which did not specifically include in its invoices rendered in accordance with those estimates. ...

After indicating that fees to clients would not qualify under s. 118.2(2)(a) because the individual was not a health practitioner, CRA reviewed the requirements of ss. 118.2(2)(l.9) (including its interpretation in Herzig) and 118.4(1)(c) noted inter alia that “no other activity, including work, housework, and social or recreational activities, is considered a basic activity of daily living.” ...

CRA stated: Subsection 12(9.1) provides that where a taxpayer disposes of an interest in a debt obligation in respect of which the taxpayer's share of the principal payments is unequal to the taxpayer's share of the interest payments on that obligation, the portion of the proceeds of disposition that can reasonably be considered to represent a recovery of the cost to the taxpayer of the interest in the debt obligation will not be included in computing the income of the taxpayer. … The CRA is of the view that an obligation such as the one described in the above example is not an obligation described in paragraph 7000(1)(b) and therefore the provisions of subsection 12(9.1) do not apply. ...

CRA indicated that it considered that “the premium paid by AB Inc. for the benefit of A and B constitutes a benefit received by them in their capacity as shareholders,” so that the benefit from such payment was not excluded by s. 6(1)(a)(i). ...

2 March 2007 External T.I. 2006-0185471E5 F- Frais de représentation- 67.1-- summary under Subsection 236(1) Summary Under Tax Topics- Excise Tax Act- Section 236- Subsection 236(1) ITA s. 67.1 agreement as to portion of remote work site daily allowances to be treated as for meals rather than accommodation also applies to ETA s. 236 CRA confirmed a 1998 agreement regarding, where employees received a daily allowance to cover the costs of meals and accommodation while away from home and at a remote work site, what portion of the allowances was to be considered to be the meal expense portion that was subject to the ETA s. 236(1) ITC limitation: Amount of daily allowance Meal portion $75 and under 15% of the balance Between $75 and $100 $11.25 plus 20% of the balance Between $100 and $125 $16.25 plus 30% of the balance Over $125 $23.75 plus 40% of the balance ...

An amount can generally be considered a special allowance when it is paid to an employee who is transferred or posted abroad and thus incurs additional expenses. ...

The age and health of the insured, the value of the accumulation fund, the cash surrender value and the amount of premiums paid at the date of transfer are all factors to be considered in determining the FMV. ...