(1.1)-(23)

Subsection 6(1.1) - Parking cost

Subsection 6(2) - Reasonable standby charge

See Also

Szymczyk v. The Queen, 2014 TCC 380 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Estoppel Minister's authorization should not be set aside too readily as being contrary to law 317
Tax Topics - General Concepts - Onus Minister's "partly arbitrary" assumptions did not remove onus from taxpayer 317
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) late designation not permitted/rule-of-thumb method invalidated by s. 6(1)(k) 189

Keefe v. The Queen, 2003 DTC 1526, 2003 TCC 791 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
substantially all

Guignard v. The Queen, 2002 DTC 2092 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

McDonald v. The Queen, 98 DTC 2151 (TCC) (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Deputy Minister of Revenue (Quebec) v. Rodrigue, 95 DTC 5475 (Que. C.A.)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

6 October 2017 APFF Roundtable, Q.13

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9 March 2017 External T.I. 2017-0689241E5 F - Avantages imposables relatifs aux automobiles ou autres véhicules

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Automobile emergency vehicle's markings must clearly mark it as police or fire vehicle 76

12 January 2017 Internal T.I. 2016-0636911I7 - Standby Charge - PST and the cost of an automobile

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(7) car standby charge is reduced for the sales tax reduction occurring where a trade-in allowance is provided on the car purchase 153

7 October 2016 APFF Roundtable Q. 5, 2016-0652861C6 F - Véhicules électriques - rabais

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e) use of manufacturer’s electricity-use standard 88
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A installation cost included 31
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(g) vehicle assistance paid indirectly (to dealer) covered 225
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A cost not reduced under general principles by government assistance 137

18 February 2015 External T.I. 2012-0471731E5 F - Déductibilité du droit d’usage pour automobile

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) reduced auto enjoyment not an expenditure 144

27 June 1995 T.I. 950505 (C.T.O. "Automobile Benefits")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 November 2014 External T.I. 2014-0529991E5 F - Avantage pour automobile-personne liée

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) control of non-share corp references who can appoint board 131

15 February 1994 T.I. 933573 (C.T.O "Automobile Standby Charges")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 6(2.1) - Automobile salesperson

Subsection 6(2.2)

Administrative Policy

88 C.R. - "Automobile Rules" - "Employee Benefits"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 6(3) - Payments by employer to employee

Commentary

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Cases

Morissette v. Canada, 2008 DTC 6513, 2007 FCA 16

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Markin v. The Queen, 96 DTC 6483 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Blanchard, 95 DTC 5479 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

McNeill v. The Queen, 86 DTC 6477, [1986] 2 CTC 352 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Moss v. MNR, 63 DTC 1359 (Ex Ct)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Curran v. Minister of National Revenue, 59 DTC 1247, [1959] S.C.R. 850

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 3 185

See Also

Desmarais c. La Reine, 2008 DTC 3830, 2006 TCC 417

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Richstone v. MNR, 72 DTC 6232, [1972] CTC 265 (FCTD), briefly aff'd 74 DTC 6129 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality covenant respected until invalidated 73
Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(e) 70

Wilson v. MNR, 60 DTC 115 (TAB)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

S2-F3-C1 - Payments from Employer to Employee

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Dual-purpose payments

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-196R2 "Payments by Employer to Employee"

Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt 37

Paragraph 6(3)(b)

Cases

Greiner v. The Queen, 81 DTC 5371, [1981] CTC 477 (FCTD), aff'd 84 DTC 6073, [1984] CTC 92 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Quance v. The Queen, 74 DTC 6210, [1974] CTC 225 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

28 July 2017 External T.I. 2017-0685961E5 - Taxation of Settlement Amounts

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance settlement amount (re post-retirement benefits reduction) also paid to current employees likely not retiring allowance 163
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) amounts received in settlement of employment grievances to be s. 5 income on general principles 203

Paragraph 6(3)(c)

Cases

The Queen v. Lao, 93 DTC 5251 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

S3-F9-C1 - Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 6(3)(d)

Cases

Choquette v. The Queen, 74 DTC 6563 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

MNR v. Beaupré Estate, 73 DTC 5255, [1973] CTC 316 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 43

See Also

Gowling v. MNR, 78 DTC 1624 (TRB)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 6(3)(e)

Cases

Girouard v. The Queen, 80 DTC 6205, [1980] CTC 284 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Richstone v. MNR, 72 DTC 6232, [1972] CTC 265 (FCTD), briefly aff'd 74 DTC 6129 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality covenant respected until invalidated 73
Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) 208

See Also

No. 115 v. MNR, 53 DTC 338 (ITAB)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Substance 101

Beak v. Robson (1942), 15 TC 33 HL

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

27 June 2014 External T.I. 2014-0526931E5 F - Vente d'une liste de clients par un employé

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure payment to departing employee for customer list was on capital account 47

20 December 2002 Internal T.I. 2002-0147967 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition 25
Tax Topics - Income Tax Act - Section 9 - Compensation Payments termination of advisory agreemment with external MFT manager gave rise to capital receipt 267

9 November 1999 External T.I. 5-991265 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

17 October 1997 Ruling 97110

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

8 February 1991 TI

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 6(3.1) - Amount receivable for covenant

Administrative Policy

S2-F3-C1 - Payments from Employer to Employee

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 6(4) - Group term life insurance

Administrative Policy

S2-F1-C1 - Health and Welfare Trusts

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

December 1992 B.C. Tax Executives Institute Round Table, Q.9 (October 1993 Access Letter, p. 480)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

December 1992 B.C. Tax Executive Institute Round Table, Q.8 (October 1993 Access Letter, p. 479)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

14 April 1992 T.I. (Tax Window, No. 18, p. 16, ¶1858)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 6(6) - Employment at special work site or remote location

Cases

Truemner v. The Queen, 89 DTC 5149 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Demers, 81 DTC 5256, [1981] CTC 282 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Forestell, 79 DTC 5289, [1979] CTC 370 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Spannier v. The Queen, 2013 TC 40

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
maintain

Bergeron v. The Queen, 2011 DTC 1098 [at 534], 2010 TCC 56

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Dupuis v. The Queen, 2009 DTC 1386, 2009 TCC 220 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
temporary

Pozumiak v. The Queen, 2006 DTC 2165, 205 TCc 811

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Guilbert v. MNR, 91 DTC 740 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

12 February 2015 External T.I. 2014-0550771E5 F - Allocation à des bénévoles - chantier particulier

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts mission work volunteers foregoing allowances 96
Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit modest compensation to volunteers qua independent contractors not income 98
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) quite unrepresentative remuneration: exempt 98

15 December 2014 Internal T.I. 2014-0544121I7 F - Chantier particulier

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
temporary nature

30 December 2013 External T.I. 2013-0502641E5 - Transportation Allowance

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

17 July 2012 Internal T.I. 2011-0421921I7 - Special work site and remote work location

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

21 August 1996 Memorandum 961857 [coast guard vessel away for under 36 hours]

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

30 June 1995 Memorandum 951108 (C.T.O. "Special Work Site Travel and Accommodation Allowance")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

17 February 1994 T.I. 932533 (C.T.O. "Special Work Sites")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

17 November 1993 Memorandum 932243 (C.T.O. "Special Work Site")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

23 March 1992 T.I. (Tax Window, No. 18, p. 16, ¶1826)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2 April 1990 Memorandum (September 1990 Access Letter, ¶1406)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

88 C.R. - F.Q.1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Novek, "Employment Benefits May be Tax-Free If Provided in Connection with Special Worksite or Remote Location", Taxation of Executive Compensation and Retirement, October 1991, p. 505.

Paragra;h 6(6)(a)

Administrative Policy

19 January 2015 External T.I. 2014-0549061E5 F - logement des employés

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 6(7)

Administrative Policy

12 January 2017 Internal T.I. 2016-0636911I7 - Standby Charge - PST and the cost of an automobile

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) cost for standby charge purposes reduced by sales tax reduction attributable to trade-in 49

Subsection 6(11) - Salary deferral arrangement

Administrative Policy

21 November 2016 Internal T.I. 2016-0641961I7 F - DSU Plan

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(d) - Subparagraph 6801(1)(d)(i) potential change-of-control redemption trigger (and Code s. 409A triggers) were offside 165

29 April 2015 External T.I. 2015-0565181E5 - Amendment to DSU plan

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(d) termination of Plan contrary to DSU rules triggered retroactive application of SDA rules 191

Articles

David Nathanson, "Included Versus Reported", Canadian Tax Highlights, Vol. 24, No. 9, September 2016, p. 5

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
included

Jim Kahane, Uros Karadzic, Simon Létourneau-Laroche, "A Fresh Look at Retirement Compensation Arrangement: A Flexible Vehicle for Retirement Planning", Canadian Tax Journal (2013) 61:2, 479 – 502.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 6(13) - Application

Articles

Miller, "Tax Considerations for U.S. Citizens Moving to Canada", 1993 Corporate Management Tax Conference Report, c. 16.

Subsection 6(15) - Forgiveness of employee debt

Administrative Policy

12 October 2016 Internal T.I. 2016-0637781I7 - Employee loan or debt extinguished or settled

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
settle
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a) writing-off debt was its settlement 34

10 February 1992 T.I. (Tax Window, No. 16, p. 12, ¶1742)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares 24

4 November 1991 Memorandum (Tax Window, No. 13, p. 11, ¶1585)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(1) 29

Subsection 6(15.1) - Forgiven amount

See Also

Rémillard v. The Queen, 2011 DTC 1286 [at 1617], 2011 TCC 327

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 6(22) - Eligible housing loss

See Also

Thomas v. The Queen, 2005 DTC 1527, 2005 TCC 613

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

Subsection 6(23) - Employer-provided housing subsidies

Administrative Policy

25 May 2001 External T.I. 2001-007831 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

The Queen v. Proulx, 2010 DTC 5028 [at 5609], 2010 FCA 261

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.