Paragraph 6(1)(b) - Personal or living expenses
Cases
Bériault v. Canada, 2004 DTC 6522, 2003 FCA 430
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Rio v. Canada (Attorney General), 2004 DTC 6079, 2003 FCA 396
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The Queen v. Côté, 99 DTC 5788, 1999 CanLII 8469 (FC) (FCTD)
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Words and Phrases
allowanceVerdon v. The Queen, 98 DTC 6175 (FCA)
Attorney General of Canada v. MacDonald, 94 DTC 6262, [1994] 2 CTC 48 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | 82 |
Blanchard v. The Queen, 92 DTC 6585, [1992] 2 CTC 403 (FCTD)
Splane v. The Queen, 90 DTC 6442, [1990] 2 CTC 199 (FCTD), briefly aff'd 92 DTC 6021 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | payment of increased house mortgage interest merely reimbursed for a loss | 112 |
See Also
Sénéchal v. The Queen, 2011 DTC 1357 [at 1997], 2011 TCC 365 (Informal Procedure)
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McLay v. MNR, 92 DTC 2260, [1992] 2 CTC 2649 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 62 | 100 |
Administrative Policy
13 April 2018 External T.I. 2017-0682891E5 - Taxable benefits
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4 December 2018 External T.I. 2016-0670851E5 - Regular Places of Employment and Personal Travel
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Words and Phrases
regular place of employment| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(b) - Subparagraph 6(6)(b)(i) | travel between temporary place of residence and special work site not excluded | 139 |
19 July 2018 External T.I. 2014-0551941E5 F - Déplacement effectué par un employé
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Words and Phrases
regular place of employment28 April 2017 Internal T.I. 2017-0699741I7 - Phoenix - financial advisor funding
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2 October 2014 External T.I. 2013-0491411E5 F - Allocation pour une automobile
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 | compensation for car rides not received in the course of employment or a business | 184 |
May 2016 Alberta CPA Roundtable, Q.3
S2-F3-C2 - Benefits and Allowances Received from Employment
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Words and Phrases
allowance5 July 2015 External T.I. 2015-0588201E5 F - Apportez vos appareils personnels / BYOD
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7 April 2015 External T.I. 2014-0552731E5 F - Apportez vos appareils personnels / BYOD
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Words and Phrases
allowance18 December 2014 External T.I. 2014-0523711E5 F - Allocation pour déménagement - achat de meubles
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | allowance that is capped at documented expenses might not be an allowance/reimbursing new furniture might be taxable benefit | 228 |
1 October 2014 External T.I. 2013-0476081E5 F - Allocation pour une automobile
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14 February 2014 Internal T.I. 2013-0495661I7 - Taxability of payment from US charitable trust
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) | financial assistance to former charity employee | 88 |
5 October 2012 Roundtable, 2012-0454131C6 F - Caractère raisonnable d'une allocation automobile
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30 March 2012 External T.I. 2011-0428741E5 F - Allocations pour frais de déplacement
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24 April 2012 Internal T.I. 2012-0440711I7 F - Indemnité de repas; remboursement pour déplacement
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27 September 2011 External T.I. 2011-0400141E5 F - Allocations pour frais de déplacement
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11 March 2010 External T.I. 2009-0345481E5 F - Allocations versées administrateurs bénévoles
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Office | definition of a “volunteer” (who is excluded from the holder of an “office”) | 121 |
19 May 2010 External T.I. 2009-0342651E5 F - Remboursement de dépenses et allocations
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| Locations of other summaries | Wordcount | |
|---|---|---|
| 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(23) | reimbursement of expenses to obtain a mortgage is included | 35 |
30 November 1995 Ruling 9632153 - OPTIONS WITH SAR RIGHTS
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8 February 2010 Internal T.I. 2009-0352721I7 F - Allocations pour frais de repas
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii) | meaning of regular place of employment | 168 |
29 June 1995 Internal T.I. 9511147 - TAXABLE BENEFITS AND ALLOWANCES - CLEANING
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26 July 1994 T.I. (C.T.O. "Employment Benefits - Special Clothing")
9 February 1994 Internal T.I. 9335877 - TAXABLE BENEFITS - CLOTHING ALLOWANCE
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(i) - Subparagraph 8(1)(i)(iii) | 115 |
13 December 1993 External T.I. 9326335 - TRANSFER ALLOWANCE
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11 March 1993, T.I. (Tax Window, No. 30, p. 13, ¶2465)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 70 |
5 January 1993 T.I. (Tax Window, No. 28, p. 15, ¶2402)
21 July 1992 Memorandum 921671 (March 1993 Access Letter, p. 64, ¶C5-184)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 19 |
Forms
T4130 Employers' Guide - Taxable Benefits and Allowances
Subparagraph 6(1)(b)(iii)
Administrative Policy
30 September 2011 Internal T.I. 2011-0393171I7 F - Representation or other special allowances
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | no benefit for excess of rent allowance over cost of comparable Cdn location or where higher class of accommodation is for security reasons | 259 |
28 June 2010 External T.I. 2010-0361561E5 F - Programme d'aide au développement international
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| Tax Topics - Income Tax Regulations - Regulation 3400 | exclusion for international aid program | 114 |
Subparagraph 6(1)(b)(v)
Cases
Hudema v. The Queen, 94 DTC 6287 (FCTD)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) | 135 |
The Queen v. Eggert, 85 DTC 5522, [1985] 2 CTC 343 (FCTD)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii) | 32 | |
| Tax Topics - Statutory Interpretation - Punctuation | 20 |
Administrative Policy
S2-F3-C2 - Benefits and Allowances Received from Employment
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Subparagraph 6(1)(b)(vii)
Cases
Canada (National Revenue) v. Al Saunders Contracting & Consulting Inc., 2020 FCA 89
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. | Technical Notes add context to interpretation | 106 |
The Queen v. Eggert, 85 DTC 5522, [1985] 2 CTC 343 (FCTD)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(v) | 29 | |
| Tax Topics - Statutory Interpretation - Punctuation | 20 |
The Queen v. Paradis, 86 DTC 6029, [1985] 2 CTC 3 (FCTD)
The Queen v. Cival, 83 DTC 5168, [1983] CTC 153 (FCA)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h) - Subparagraph 8(1)(h)(ii) | 53 |
The Queen v. Lavers, 78 D.T.C 6230, [1978] CTC 341 (FCTD)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 172 - Subsection 172(1) | 39 |
See Also
Hamilton v. The Queen, 2020 TCC 23 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(b) - Subparagraph 6(6)(b)(i) | per-kilometer travel allowance calculated re distance between remote location and central point in employee’s city did not qualify | 161 |
Morissette v. The Queen, 2013 DTC 1002 [at 21], 2012 TCC 37 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 99 |
Sénéchal v. The Queen, 2011 DTC 1357 [at 1997], 2011 TCC 365 (Informal Procedure)
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Administrative Policy
Canada Revenue Agency increases flat rate amount for meal claims, and reasonable amount for meal benefits and allowances 3 September 2020 CRA Press Release
8 November 2019 External T.I. 2019-0820401E5 - Temporary Residence Allowance
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15 November 2016 Internal T.I. 2015-0577201I7 F - Employés du transport
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Words and Phrases
allowance8 February 2010 Internal T.I. 2009-0352721I7 F - Allocations pour frais de repas
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Words and Phrases
regular place of employment| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) | no taxable benefit from $17 meal allowance paid where 2 or more hours of occasional contiguous overtime | 190 |
Subparagraph 6(1)(b)(vii.1)
Cases
See Also
Sénéchal v. The Queen, 2011 DTC 1357 [at 1997], 2011 TCC 365 (Informal Procedure)
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Veinot v. The Queen, 2010 DTC 1097 [at 3017], 2010 TCC 112 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) | 202 |
Administrative Policy
5 March 2021 External T.I. 2017-0713041E5 F - Allocation pour usage d’un véhicule à moteur
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(x) | it can be acceptable to cap the kilometres for which a car allowance is paid | 222 |
17 August 2020 External T.I. 2016-0643631E5 F - Frais de déplacement
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Words and Phrases
regular place of employment| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) | commuting expenses to a 2nd more distant regular employer establishment were personal | 110 |
2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.5, 2016-0674801C6 F - Allocation et frais d'une automobile
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) - Subparagraph 6(1)(k)(v) | electric vehicles treated the same | 62 |
19 December 2012 External T.I. 2012-0463581E5 F - Allocation pour l'usage d'un véhicule
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25 January 2010 Internal T.I. 2009-0345501I7 F - Allocations pour frais de déplacement
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(b) - Subparagraph 6(6)(b)(i) | potential application to track maintenance employees | 126 |
26 January 2009 Internal T.I. 2008-0303901I7 F - Allocation raisonnable et coûts d'opération
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29 August 2008 External T.I. 2007-0257661E5 F - Allocation pour frais de déplacement
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13 June 2008 External T.I. 2008-0270721E5 F - Allocations pour l'usage d'un véhicule à moteur
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3 December 1993 Internal T.I. 9324577 - AUTOMOBILE ALLOWANCE, LESS THAN REASONABLE AMOUNT?
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90 C.R. - Q3
88 C.R. - "Automobile Rules" - Allowances to Employees"
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(x) | 92 |
Subparagraph 6(1)(b)(x)
Administrative Policy
5 March 2021 External T.I. 2017-0713041E5 F - Allocation pour usage d’un véhicule à moteur
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii.1) | unreasonably low allowance may be taxable | 304 |
24 June 2016 Internal T.I. 2014-0555611I7 F - Allocation raisonnable
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17 June 2013 External T.I. 2012-0465031E5 F - Paiements pour publicité sur un véhicule
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|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | taxable benefit from being paid to display company logo on car | 84 |
28 March 2013 External T.I. 2012-0460481E5 F - Allocation pour usage d'un véhicule à moteur
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22 June 2011 External T.I. 2010-0387391E5 F - Allocations pour véhicule à moteur
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) | employees entitled to s. 8(1)(h.1) deduction where they received an allowance that was taxable under s. 6(1)(b)(x) | 161 |
20 July 2009 External T.I. 2009-0312541E5 F - Allocation pour usage d'un véhicule à moteur
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) | T2200 can be prepared where car allowance bifurcated into 2 allowances, one of which is taxable | 266 |
7 May 2007 Internal T.I. 2007-0228521I7 F - Allocation pour frais de déplacement
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2 May 1990 T.I. (October 1990 Access Letter, ¶1448)
88 C.R. - "Automobile Rules" - Allowances to Employees"
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii.1) | 25 |
Subparagraph 6(1)(b)(xi)
Administrative Policy
8 February 1994 Internal T.I. 9400657 - EMPLOYMENT EXPENSES
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Words and Phrases
reimbursementOctober 1989 Revenue Canada Round Table - Q1 (Jan. 90 Access Letter, ¶1075)
Paragraph 6(1)(c) - Director’s or other fees
Administrative Policy
17 December 2012 External T.I. 2012-0458071E5 - Per Diem Fees
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Office | 96 |
Paragraph 6(1)(e) - Standby charge for automobile
Cases
Babich v. Canada, 2013 DTC 5010 [at 5556], 2012 FCA 276, aff'g 2010 TCC 352
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | shareholder rather than employee benefit | 194 |
Canada v. Adams, 98 DTC 6266 (FCA)
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See Also
Potvin v. The Queen, 2008 DTC 4813, 2008 TCC 319 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | negligible work - therefore shareholder benefit | 86 |
Administrative Policy
23 February 2012 External T.I. 2011-0423461E5 F - Automobiles de collection
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7 October 2016 APFF Roundtable Q. 5, 2016-0652861C6 F - Véhicules électriques - rabais
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | installation cost included | 37 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) | Quebec government assistance does not reduce cost of purchased vehicle, but treated as compensation to dealer-lessor prorated over term of lease | 259 |
| 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 |
7 September 2012 Internal T.I. 2012-0434341I7 - Taxable benefit chauffeur of employer-provided car
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9 December 2010 Internal T.I. 2010-0371741I7 F - Automobiles mises à la disposition des employés
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Automobile | qualification as automobiles turns on design, not use | 164 |
6 August 2010 External T.I. 2010-0364091E5 F - Utilisation d'un véhicule fourni par l'employeur
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November 1991 Memorandum (Tax Window, No. 12, p. 7, ¶1568)
2 November 89 Policy and Systems Branch Letter (May 1990 Access Letter, ¶1204)
89 C.R. - Q.48
IT-63R5 "Benefits, Including Stand-By Charge for an Automobile, from the Personal Use of a Motor Vehicle Supplied by an Employer - after 1992"
Articles
M. Tang, G. Katz, "Automobile Taxable Benefits and Expenses: Part 1", 1997 Canadian Tax Journal, Vol. 45, No. 5, p. 1150.
Summerville, "Stand-by Charge May Be Reduced by Leaving Company Car in Employer's Control", Taxation of Executive Compensation and Retirement, September 1990, p. 326.
Paragraph 6(1)(e.1) - Group sickness or accident insurance plans
Administrative Policy
12 June 2017 Internal T.I. 2016-0679291I7 F - Régime d’assurance décès et mutilation accidentels
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Words and Phrases
group plan29 April 2013 External T.I. 2013-0476131E5 F - Régime d'assurance-collective
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(4) | general description of the s.6(4) exception to s. 6(1)(a)(i) | 160 |
IT-63R5 "Benefits, Including Stand-By Charge for an Automobile, from the Personal Use of a Motor Vehicle Supplied by an Employer - after 1992"
Paragraph 6(1)(f) - Employment insurance benefits
Commentary
Cases
Tsiaprailis v. Canada, 2005 DTC 5119, 2005 SCC 8, [2005] 1 S.C.R. 113
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See Also
Eyckelhoff v. The Queen, 2020 TCC 130 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) | foreign policy generated taxable pension given failure to establish that it was a taxpayer-funded disability policy | 242 |
Watts v. The Queen, 2004 DTC 3111, 2004 TCC 535 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.94 | 39 | |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) | 77 |
Harnish v. The Queen, 2007 DTC 1317, 2007 TCC 546 (Informal Procedure)
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Fry v. The Queen, 2001 DTC 846 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | 52 |
Cook v. The Queen, 95 DTC 853, [1995] 1 CTC 2251 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 97 |
Administrative Policy
2019 Ruling 2018-0757561R3 - Payment in lieu of continued WLRP payments
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(b) | residual payments out of a disability trust were employment income | 133 |
S2-F1-C1 - Health and Welfare Trusts
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Employee contributions
8 July 2013 Internal T.I. 2012-0470021I7 - Settlement of Future Benefits ASO Plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) - Subparagraph 39(1)(a)(ii) | 244 |
12 February 2013 Internal T.I. 2013-0475631I7 - Treatment of Settlement Amounts
23 March 2009 External T.I. 2008-0293131E5 F - Prestations reçues par une succession
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 70 - Subsection 70(2) | amounts received by estate in settlement of deceased’s action for unpaid disability were rights and things | 199 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit | survivor benefit in settlement of rights under a wage loss replacement plan could be a death benefit | 143 |
3 November 2008 External T.I. 2008-0289701E5 F - Paiement fait à la succession d'un employé
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24 August 2007 External T.I. 2006-0215691E5 F - Ristourne d'un régime d'assurance collective
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27 March 2007 External T.I. 2006-0217511E5 F - Régime d'assurance collective
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | payment by employer of all rather than half the premiums for a group insurance plan would not oust the exclusion | 137 |
22 November 2006 External T.I. 2006-0189441E5 - Change to employer paid disability plan
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30 January 2006 External T.I. 2005-0159331E5 - Long term disability lump sum payments
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31 July 2002 External T.I. 2002-0145335 - WAGE LOSS REPLACEMENT PLAN - TAX STATUS
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3 November 2000 External T.I. 2000-0050685 - LTDP IS AN EMPLOYEE-PAY-ALL PLAN
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5 July 1995 External T.I. 9507035 - DISABILITY PLANS WITH EMPLOYEE PAY OPTION
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22 June 1994 External T.I. 9409815 - WAGE LOSS REPLACEMENT PLANS
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9 June 1994 Internal T.I. 9405947 - SETTLEMENT OF DAMAGES
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15 February 1994 External T.I. 9329835 - CONVERSION OF AN LTD PLAN
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16 December 1993 External T.I. 9320395 - EMPLOYEE PAY ALL ACCIDENT INSURANCE PLANS
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2 November 1992 T.I. 922363 (September 1993 Access Letter, p. 404, ¶C5-212)
20 August 1992 Memorandum 922092 (April 1993 Access Letter, p. 130, ¶C5-190; Tax Window, No. 23, p. 21, ¶2159)
18 February 1992, T.I. 913508 (March 1993 Access Letter, p. 65, ¶C5-185)
14 February 1992 T.I. 193385 (January - February 1993 Access Letter, p. 7, ¶C5-182)
28 January 1992 Memorandum (Tax Window, No. 16, p. 17, ¶1723)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(g.1) | 64 |
11 July 1991 Memorandum (Tax Window, No. 6, p. 11, ¶1349)
8 May 1991 T.I. (Tax Window, No. 3, p. 28, ¶1246)
Subparagraph 6(1)(f)(v)
Paragraph 6(1)(g) - Employee benefit plan benefits
Administrative Policy
5 October 2020 External T.I. 2020-0852671E5 - Provident fund - Isle of Man
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) | pension fund payments are carved out of EPB benefits where s. 6(1)(g)(iii) applies | 332 |
3 July 2019 External T.I. 2018-0781941E5 - Foreign retirement plans (Ireland)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit | employer contributions to a predecessor fund are insufficient to give rise to superannuation or pension benefits | 196 |
Paragraph 6(1)(i)
Administrative Policy
2015 Ruling 2015-0601441R3 - XXXXXXXXXX Partnership - winding up
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) | 98(5) wind-up through s. 85 transfer of partnership interest of one partner to the other and preceded by debt assumptions | 292 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) | interest deductible following assumption of interest-bearing internal debt on s. 98(5) wind-up | 297 |
| Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(11) | continuation of s. 34.2(11) reserve following partnership wind-up | 336 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | continued availability of s. 20(1)(m) reserve following s. 98(5) wind-up | 284 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) | flow-through of s. 20(1)(n) reserve on s. 98(5) wind-up | 280 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) | s. 20(24) election on s. 98(5) wind-up | 298 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) | s. 18(9) deduction claimable by transferee former partner following s. 98(5) wind-up | 232 |
| Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(8) | s. 147.2 continuity following s. 98(5) wind-up | 356 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement - Paragraph (k) | no income on RSU/DSU assumption | 22 |
Paragraph 6(1)(j)
Administrative Policy
11 March 2009 External T.I. 2009-0306601E5 F - Remboursement de cotisations syndicales
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) | Fries applied re exempt distributions from a union | 39 |
5 March 2009 External T.I. 2008-0279241E5 F - Prestation consécutive au décès
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit | benefit paid on union member’s death could not be a death benefit (no employer-employee relationship | 30 |
| Tax Topics - Income Tax Act - Section 70 - Subsection 70(2) | lump sum paid to a union member on death could be in satisfaction of a right or thing | 193 |
Paragraph 6(1)(k) - Automobile operating expense benefit
See Also
Szymczyk v. The Queen, 2014 TCC 380 (Informal Procedure)
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| 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 | 329 |
| Tax Topics - General Concepts - Onus | Minister's "partly arbitrary" assumptions did not remove onus from taxpayer | 333 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) | separate personal use kilometers required for each vehicle used in year | 183 |
Administrative Policy
17 July 2019 External T.I. 2018-0777951E5 F - Avantage automobile
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(2) | where 2 related employers, only a single benefit under the formula is calculated for each automobile | 115 |
| 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 |
14 September 2017 Roundtable, 2017-0703881C6 - CPA Alberta 2017 Q17: Electric Vehicle Taxable Benefits
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | benefit from employer-provided charging station | 205 |
| Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) | requirements for employee deduction of electricity costs for home vehicle charging station | 170 |
17 December 2013 Internal T.I. 2013-0510111I7 F - Automobile mise à la disposition d'un employé
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Words and Phrases
workplace5 October 2012 Roundtable, 2012-0454151C6 F - Registre des déplacements
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 230 - Subsection 230(1) | no stipulated documentary requirement for kilometer log | 125 |
26 June 1995 Internal T.I. 9500886 - AUTOMOBILE OPERATING EXPENSE BENEFIT
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14 March 1995 External T.I. 9428915 - WHETHER TRAVEL PERSONAL OR BUSINESS
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IT-63R5 "Benefits, Including Stand-By Charge for an Automobile, from the Personal Use of a Motor Vehicle Supplied by an Employer - after 1992"
Articles
Yull, "New Automobile Rules Call for a Review of Remuneration Strategy", Taxation of Executive Compensation and Retirement, March 1994, p. 883.
Subparagraph 6(1)(k)(v)
Administrative Policy
2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.5, 2016-0674801C6 F - Allocation et frais d'une automobile
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii.1) | general reasonability of a car allowance rate of $0.54/$0.48 per kilometre including for electric vehicles | 184 |
Commentary