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If both the top up for the life insurance and the top up for the long term disability are self- insured using the same trust and one of the plans is considered an EBP, the combined plan will likely be an EBP as indicated in paragraph 4 of IT-502, "Employee Benefit Plans and Employee Trusts". ...

Also, as indicated in paragraph 10(a) of IT-352R2, the cost of a second telephone line, even if used exclusively for work purposes, is considered non-deductible for the purposes of subparagraph 8(1)(i)(iii) of the Act. ...

Since a liability is not considered to be a property, there are no provisions of the Act other than subsection 39(2) to deal with a foreign exchange gain or loss on account of capital, on the repayment in whole or in part of a debt. ...

2 June 2008 External T.I. 2008-0264161E5 F- Benefit Conferred to a Shareholder Unedited CRA Tags 15(1) 246(1) 56(2) Principal Issues: In a given situation, where the parents of the shareholder of a corporation have the exclusive use of a residence owned by the corporation at no charge, whether it could be considered for the purposes of subsection 15(1) that the corporation conferred a benefit either to the shareholder or the parents? ...

As far as the CCPC recipient is concerned, the CRA would generally accept that the recipient CCPC adds to its GRIP the part of the dividend that is covered by safe income (the "safe dividend"), provided that the CCPC recipient made or makes a designation under paragraph 55(5)(f) of the ITA in order that the safe dividend be considered a separate taxable dividend. ...

It further indicates that if the agreement under which an amount is paid gives rise at the time of payment to an enforceable debt, it is the view of the CRA that the amount is a loan, but if the agreement specifies that the amount paid does not become a debt of the recipient unless the recipient fails to fulfil certain conditions, the amount is generally considered to be a repayable award. ...

It is considered significant if an individual is not entitled to receive the bonus unless he or she is an active employee at the time of the payment. ...

Whether an undivided interest in farmland could be considered qualified farm property as defined in subsection 110.6(1)? ...

In a situation where the shareholder's agreement provides that the life insurance policy would be used for the purchase of the shares of a deceased shareholder from his estate, it would be a relevant factor to be considered in determining a main purpose of the acquisition of a life insurance policy. ...

Paragraph 6 of Interpretation Bulletin IT-342R "Trusts- Income Payable to Beneficiaries" (March 21, 1990) comments on the timing of an income inclusion as follows: The amounts required to be included in computing the income of a beneficiary for a taxation year under subsections 104(13) and 105(2) are considered to have been earned by the beneficiary on the last day of the taxation year of the trust and are thus in respect of the taxation year or years of the trust which ended in the taxation year of the beneficiary. [...]. ...