(1.1)-(23)

Table of Contents

Subsection 6(1.1) - Parking cost

Subsection 6(2) - Reasonable standby charge

See Also

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

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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)

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Words and Phrases
substantially all

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

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

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

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Administrative Policy

17 July 2019 External T.I. 2018-0777951E5 F - Avantage automobile

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Tax Topics - Income Tax Regulations - Regulation 200 - Subsection 200(3) where 2 related employer, ss. 6(1)(e) or (k) benefit can be reported by either employer 174
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) two related joint employers should agree on which of them will T4 an employee for the single s. 6(1)(e) or (k) benefit for the car provided by one of them to him 107

6 October 2017 APFF Roundtable Q. 13, 2017-0709061C6 F - Calcul des frais pour droit d'usage

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

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Automobile emergency vehicle's markings must clearly mark it as police or fire vehicle 78

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

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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 165

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

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e) use of manufacturer’s electricity-use standard 94
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A installation cost included 37
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(g) vehicle assistance paid indirectly (to dealer) covered 237
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A cost not reduced under general principles by government assistance 139

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

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Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) reduced auto enjoyment not an expenditure 154

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

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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 143

7 February 2014 External T.I. 2014-0516921E5 F - Crédit et frais résiduels

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property lease/sale distinction established based on the legal relationship 107
Tax Topics - General Concepts - Substance lease characterized as lease unless its actual legal effects differ 148
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A lease under which lessee bore all risk implicitly treated as lease rather than purchase 177

10 September 2012 External T.I. 2012-0446921E5 F - Avantage pour automobile

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(e.4) car acquired at cost equal to FMV for standby charge purpose notwithstanding s. 85(1) election 155

6 September 2011 Internal T.I. 2011-0401191I7 F - Automobiles mises à la disposition des employés

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14 July 2010 External T.I. 2010-0361431E5 F - Usage d'une automobile fournie par l'employeur

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27 June 1995 External T.I. 9505055 - AUTOMOBILE BENEFITS

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15 February 1994 External T.I. 9335735 - AUTOMOBILE STANDBY CHARGES

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Element B

Administrative Policy

15 March 2010 Internal T.I. 2009-0323081I7 F - Frais pour droit d'usage

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Element E

Administrative Policy

28 October 2010 Internal T.I. 2010-0376041I7 F - Contrat d'acquisition ou de location

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A lease where lessee got benefits of ownership even if it didn’t acquire title not necessarily a lease 135
Tax Topics - General Concepts - Substance contracts (e.g., leases) generally not recharacterized in the absence of sham 267

Subsection 6(2.1) - Automobile salesperson

Subsection 6(2.2)

Administrative Policy

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

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Subsection 6(3) - Payments by employer to employee

Commentary

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Cases

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

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

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

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

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

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

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Tax Topics - Income Tax Act - Section 3 185

See Also

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

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

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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)

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Administrative Policy

S2-F3-C1 - Payments from Employer to Employee

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13 September 2012 Internal T.I. 2012-0442671I7 F - Dédommagement pour la perte de bénéfices

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Words and Phrases
in lieu of arises pursuant to
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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) damages received after 2011 by employees of an insolvent company for cancellation of their medical plan have become taxable 318
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit damages received for loss of life insurance coverage were not rendered a death benefit under the surrogatum principle 319
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(b) legal fees paid to recover damages for employer cancellation of insurance coverage, and medical plan, qualified and did not qualify, respectively 353

Dual-purpose payments

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IT-196R2 "Payments by Employer to Employee"

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Tax Topics - General Concepts - Payment & Receipt 37

Paragraph 6(3)(a)

Administrative Policy

4 November 2010 Internal T.I. 2010-0358441I7 F - Indien, avance de salaire

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Tax Topics - Other Legislation/Constitution - Federal - Indian Act - Section 87 salary advance cannot be exempt 151
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) salary repayment could generate non-capital loss 147
Tax Topics - Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss s. 8(1)(n) deduction could generate NCL 34

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)

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

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Administrative Policy

2019 Ruling 2018-0757561R3 - Payment in lieu of continued WLRP payments

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) lump sums received in settlement of future wage loss disability benefits were exempt 409

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

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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 171
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 211

Paragraph 6(3)(c)

Cases

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

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Administrative Policy

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

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Paragraph 6(3)(d)

Cases

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

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

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Tax Topics - General Concepts - Evidence 43

See Also

Gowling v. MNR, 78 DTC 1624 (TRB)

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Administrative Policy

20 March 2013 Internal T.I. 2013-0480201I7 F - Montants forfaitaires - XXXXXXXXXX

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Tax Topics - Income Tax Act - 101-110 - Section 110.2 - Subsection 110.2(1) - Qualifying Amount portion of wage discrimination award that related to loss of salary (based on days’ worked) would be qualifying amount 178

Paragraph 6(3)(e)

Cases

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

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

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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)

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Tax Topics - General Concepts - Substance 101

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

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

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Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure payment to departing employee for customer list was on capital account 53

20 December 2002 Internal T.I. 2002-0147967 - TAX IMPLICATIONS CONTRACT TERMINATION

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Tax Topics - Income Tax Act - Section 54 - Proceeds of Disposition 27
Tax Topics - Income Tax Act - Section 9 - Compensation Payments termination of advisory agreemment with external MFT manager gave rise to capital receipt 271

9 November 1999 External T.I. 9912655 - CONFIDENTIALITY COVENANT

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17 October 1997 Ruling 97110

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8 February 1991 TI

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Subsection 6(3.1) - Amount receivable for covenant

Administrative Policy

S2-F3-C1 - Payments from Employer to Employee

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Subsection 6(4) - Group term life insurance

Administrative Policy

S2-F1-C1 - Health and Welfare Trusts

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29 April 2013 External T.I. 2013-0476131E5 F - Régime d'assurance-collective

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e.1) overview of interrelationship between ss. 6(1)(a)(i), 6(1)(e.1) and 6(4) 304

21 July 2011 External T.I. 2010-0359171E5 F - Montants forfaitaires - retraités

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit payment in lieu of cancelled term life insurance policy made to employee’s estate is death benefit – but s. 6(4) or 6((1)(a) income if paid before retired employee’s death 180

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

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

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

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

Cases

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

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

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

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See Also

Spannier v. The Queen, 2013 TC 40

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Words and Phrases
maintain

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

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

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Words and Phrases
temporary

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

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Guilbert v. MNR, 91 DTC 740 (TCC)

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Administrative Policy

28 August 2013 Internal T.I. 2013-0496861I7 F - Allocation de résidence pour les juges

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23 December 2013 External T.I. 2013-0505481E5 F - Application des paragraphes 6(6) et 110.7(1)

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Tax Topics - Income Tax Act - 101-110 - Section 110.7 - Subsection 110.7(1) interaction between ss. 6(6) and 110.7(1)(b) 51

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

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Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts mission work volunteers foregoing allowances 123
Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit modest compensation to volunteers qua independent contractors not income 106
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) quite unrepresentative remuneration: exempt 106

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

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Words and Phrases
temporary nature

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

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

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

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30 June 1995 Internal T.I. 9511087 - SPECIAL WORK SITE TRAVEL AND ACCOMODATION ALLOWANCE

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17 February 1994 External T.I. 9325335 - SPECIAL WORK SITES

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17 November 1993 Administrative Letter 9322432 - SPECIAL WORK SITE

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

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

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88 C.R. - F.Q.1

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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.

Paragraph 6(6)(a)

Administrative Policy

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

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27 September 2013 External T.I. 2012-0472981E5 F - Chantier part. - nature temporaire

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Words and Phrases
temporary nature

11 April 2011 External T.I. 2010-0382181E5 F - Emploi chantier particulier - propriétaire

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5 February 2010 Internal T.I. 2009-0348921I7 F - Application d'un jugement de la CCI

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Subparagraph 6(6)(a)(i)

Administrative Policy

29 January 2019 External T.I. 2018-0780481E5 F - Tenir un établissement domestique autonome

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Tax Topics - Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) “self-contained domestic establishment” entails expense responsibility 118

7 May 2013 External T.I. 2013-0481321E5 F - Logement sécurisé - travail de nature temporaire

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Paragraph 6(6)(b)

See Also

McEachern v. The Queen, 2018 TCC 232 (Informal Procedure)

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Administrative Policy

29 February 2012 External T.I. 2011-0427831E5 F - Chantier particulier

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Subparagraph 6(6)(b)(i)

See Also

Hamilton v. The Queen, 2020 TCC 23 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii) additional overtime meal allowance which, in practice, was generally paid at a remote work site, qualified as a travel allowance 248

Administrative Policy

4 December 2018 External T.I. 2016-0670851E5 - Regular Places of Employment and Personal Travel

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) scope of “regular place of employment" 156

7 October 2011 Roundtable, 2011-0411961C6 F - Dépenses de déplacement

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1 June 2010 External T.I. 2009-0352811E5 F - Frais de transport- chantier particulier

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25 January 2010 Internal T.I. 2009-0345501I7 F - Allocations pour frais de déplacement

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii.1) absence of any services rendered during travel indicates the travel was not in the course of employment 122

Subsection 6(7)

Administrative Policy

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

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) cost for standby charge purposes reduced by sales tax reduction attributable to trade-in 51

Subsection 6(11) - Salary deferral arrangement

Administrative Policy

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

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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 173

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

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Tax Topics - Income Tax Regulations - Regulation 6801 - Paragraph 6801(d) termination of Plan contrary to DSU rules triggered retroactive application of SDA rules 204

17 October 2008 Internal T.I. 2007-0254201I7 F - Entente d'échelonnement du traitement

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements arrangement deferred employee compensation and was an SDA 61
Tax Topics - Income Tax Act - Section 6 - Subsection 6(12) no trust created since no transfer from employer’s patrimony 135

Articles

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

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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.

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Subsection 6(12)

Administrative Policy

17 October 2008 Internal T.I. 2007-0254201I7 F - Entente d'échelonnement du traitement

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements arrangement deferred employee compensation and was an SDA 61
Tax Topics - Income Tax Act - Section 6 - Subsection 6(11) s. 6(11) deems deferred amount to be received in a year in which it has not been taxed 111

Subsection 6(14)

Administrative Policy

14 May 2019 External T.I. 2017-0737571E5 - SAR plan with dividend equivalents

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements SDA exception for SAR plans unavailable where dividend equivalents are paid in cash 321

Paragraph 6(14)(a)

Administrative Policy

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

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements additional benefit features of a supplemental pension plan treated as SDAs 440

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

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Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a) writing-off debt was its settlement 36

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

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Tax Topics - General Concepts - Fair Market Value - Shares 26

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

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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

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Subsection 6(22) - Eligible housing loss

See Also

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

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Administrative Policy

Subsection 6(23) - Employer-provided housing subsidies

Administrative Policy

19 May 2010 External T.I. 2009-0342651E5 F - Remboursement de dépenses et allocations

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) reimbursement for employment-related moving expenses, and reimbursement of accommodation and transportation where employee temporarily assigned away from normal home base, not taxable 80
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) first $650 of allowance to cover moving costs not taxable 54

25 May 2001 External T.I. 2001-0078315 - relocation expenses

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

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