Subsection 32.1(1) - Employee benefit plan deductions
Administrative Policy
1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement
Parentco (apparently, a non-resident public company) funds and administers a performance share plan (“PSP”) for employees of group companies,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) | no s. 7(3)(b) prohibition where at employer’s option to settle PSPs in cash or in shares | 250 |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) | s. 7 rules do not apply to shares purchased through a trust | 180 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Employee Benefit Plan | custodial PSP arrangement was an EBP | 190 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | recharge payments made for employees participating in parent-administered PSP not deductible to extent they were employed by affiliates during vesting period | 241 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) | request for deduction not to be allowed if based on case decision rather than error | 281 |
20 January 1994 External T.I. 9400755 - EBP'S, EPSP'S, DPSP'S AND SECTION 7
If employer contributions can only be used to purchase, on the open market, employer's shares or shares of a corporation with which it does not...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 147 - Subsection 147(8) | 33 |
ATR-17 9 February 1987 (Cancelled)
EmployerCo (a Canadian pubic corporation) will make a contribution at the end of each year to an Account of each Employee and “Approved...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Fair Market Value - Shares | public shares valued at 5-day average | 137 |
Paragraph 32.1(1)(a)
Administrative Policy
29 January 2004 External T.I. 2003-0046151E5 F - RPE - Dissolution d'une société en commandite
A limited partnership will dissolve, with its partners assuming the obligation to pay amounts owing to former employees under an employee benefit...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(a) | application of s. 96(1)(a) presumption means that future deductions that would have been available to the partnership are lost on its dissolution | 99 |