Section 60

Paragraph 60(a)

Administrative Policy

14 July 1992 External T.I. 5-921248 -

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 60(b) - Support

Cases

Broad v. Canada, 2010 DTC 5097 [at 6924], 2010 FCA 146

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.

Milliron v. Canada, 2003 DTC 5490, 2003 FCA 283 (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.

The Queen v. Arsenault, 96 DTC 6131 (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 - Income Tax Act - Section 56 - Subsection 56(12) 57

Ambler v. The Queen, 95 DTC 5401 (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.

Urichuk v. The Queen, 91 DTC 5375 (FCTD), aff'd 93 DTC 5120 (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.

Cohen v. The Queen, 91 DTC 5239 (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.

Burgess v. The Queen, 91 DTC 5076 (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.

Caston v. The Queen, 90 DTC 6297 (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.

McKimmon v. The Queen, 90 DTC 6088 (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.

Larivière v. The Queen, 89 DTC 5176 (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.

Hodson v. The Queen, 88 DTC 6001, [1988] 1 CTC 2 (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 - Statutory Interpretation - Ordinary Meaning 32

Klement v. The Queen, 87 DTC 5284, [1987] 2 CTC 27 (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.

Gagnon v. The Queen, 86 DTC 6179, [1986] 1 CTC 410, [1986] 1 S.C.R. 264

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.

Hanlin v. The Queen, 85 DTC 5052, [1985] 1 CTC 54 (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. Taylor, 84 DTC 6234, [1984] CTC 244 (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. Dorion, 81 DTC 5111, [1981] CTC 136 (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.

Juteau v. The Queen, 80 DTC 6218 (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.

Feinstein v. The Queen, 79 DTC 5236, [1979] CTC 329 (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 - Tax Avoidance 40

Trottier v. Minister of National Revenue, 68 DTC 5216, [1968] CTC 324, [1968] S.C.R. 728

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

Gibson v. The Queen, 95 DTC 749 (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.
Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt payment in kind if agreement as to the amount 79
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Amount 79

Lay v. The Queen, 95 DTC 272 (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.
Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 52

Nelson v. The Queen, 94 DTC 1003 (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.

Blais v. MNR, 92 DTC 1497 (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.
Words and Phrases
paid

Jaskot v. MNR, 92 DTC 1102 (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.

D'Anjou v. MNR, 92 DTC 1022 (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

15 November 1994 Internal T.I. 9424447 - DEDUCTIBILITY OF MAINTENANCE 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.

10 February 1994 Internal T.I. 9321867 - ALIMONY AND MAINTENANCE

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.

12 January 1993 T.I. (Tax Window, No. 28, p. 6, ¶2369)

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 June 1992 T.I. 921084 (December 1992 Access Letter, p. 15, ¶C56-204)

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.

6 April 1992 T.I. (Tax Window, No. 18, p. 21, ¶1848)

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.

3 March 1992 Memorandum (Tax Window, No. 17, p. 19, ¶1777)

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.

4 November 1991 T.I. (Tax Window, No. 13, p. 6, ¶1586)

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 June 1990 T.I. (November 1990 Access Letter, ¶1521)

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.

12 June 1990 Memorandum (November 1990 Access Letter, ¶1520)

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

Durnford, Toope, "Spousal Support in Family Law and Alimony in the Law of Taxation", Canadian Tax Journal, 1994, Vol. 42, No. 1, p. 1.

Paragraph 60(c) - Pension income reallocation

Cases

The Queen v. Kendall, 83 DTC 5134, [1983] CTC 119 (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.

Ahern v. The Queen, 82 DTC 6325, [1982] CTC 362 (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.

Howard v. The Queen, 74 DTC 6607, [1974] CTC 857 (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 - Effective Date 80

Administrative Policy

27 January 1992 Memorandum (Tax Window, No. 16, p. 4, ¶1719)

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 60(c.1)

Cases

Bergman v. The Queen, 94 DTC 6056 (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.

See Also

Weronski v. MNR, 91 DTC 1105 (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

21 July 1992 T.I. 921890 (March 1993 Access Letter, p. 70, ¶C56-217)

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 60(f) - Restrictive covenant — bad debt

See Also

McBurney v. The Queen, 84 DTC 6494, [1984] CTC 466 (FCTD), rev'd 85 DTC 5433, [1985] 2CTC 214 (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.
Words and Phrases
tuition fee

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.

Paragraph 60(i) - Premium or payment under RRSP or RRIF

Administrative Policy

18 November 2014 External T.I. 2012-0457981E5 - Restorative payment to registered 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 Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(q) employer restorative payment to RRSP or RPP to compensate for tort 159
Tax Topics - Income Tax Act - Section 204.1 - Subsection 204.1(2.1) employer restorative payment to RRSP or RPP to compensate for tort 83
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) employer restorative payment to RRSP or RPP to compensate for tort 115

Paragraph 60(j) - Transfer of superannuation benefits

Administrative Policy

24 June 2020 External T.I. 2018-0747781E5 - Australian Self-managed Super Fund

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) - Superannuation or Pension Benefit Australian “Self-managed Super Fund” was a pension plan 333

29 October 2018 External T.I. 2018-0750411E5 - Transfer from an IRA to a RRSP

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 60.01 a departing U.S. resident who has a deemed inclusion for his IRA cannot then obtain a s. 60(j) deduction for contributing actual IRA withdrawals to his RRSP 310
Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) - Clause 56(1)(a)(i)(C.1) deemed withdrawal from IRA rather than subsequent actual withdrawal included in income per s. 56(12) 225

16 May 2016 External T.I. 2015-0571591E5 - Employees Provident Fund of Malaysia

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) - Superannuation or Pension Benefit pension plan characteristics 168
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(i) Treaty-exempt receipts must be included in income and deducted from taxable income under s. 110(1)(f)(i) 91

2015 Ruling 2015-0572541R3 - Foreign Tax Credit on Transfer of 401(k) to RRSP

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 126 - Subsection 126(1) s. 60(j) deduction does not reduce foreign source income for FTC purposes 195
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax additional 10% tax on withdrawal from 401(k) plan, as income tax 123

24 September 2014 External T.I. 2014-0543091E5 - UK Personal Pension - RRSP

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) - Superannuation or Pension Benefit U.K personal pension scheme not a pension plan 117

15 January 2013 External T.I. 2012-0439641E5 - UK pension transfer to Canada

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

Faizal Valli, "Implications of Canadians Transferring a U.S. Retirement Plan to Canada", Taxation of Executive Compensation and Retirement, Vol. XV, No. 2, 2011, p. 930: Includes discussion of plan to transfer a 401(k) plan to an IRA, then to an RRSP.

Paragraph 60(j.1) - Transfer of retiring allowances

Administrative Policy

S2-F1-C2 - Retiring Allowances

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.

12 November 2014 Internal T.I. 2014-0535341I7 - Retiring Allowance transfer to RCA

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.

15 October 2010 External T.I. 2010-0364291E5 - 60(j.1)(ii) Predecessor Employer

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.

Income Tax Technical News, No. 7, 21 February 1996 (cancelled)

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.

24 July 1995 External T.I. 9515905 - PARTNERSHIPS UNDER 60(J.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.

1 June 1995 External T.I. 9511895 - TRANSFER OF PENSION AND RETIRING 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.

31 May 1995 Internal T.I. 9508876 - RELATED EMPLOYERS FOR RETIRING 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.

7 March 1995 External T.I. 9500685 - RETIRING ALLOWANCE - EMPLOYED

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 November 1994 External T.I. 9423845 - PARAGRAPH 60(J.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.

14 September 1994 Internal T.I. 9423527 - RETIRING ALLOWANCE FOR MLA'S

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.

12 September 1994 External T.I. 9417285 - RELATED EMPLOYERS FOR RETIRING ALLOWANCE TRANSFER

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.

4 August 1994 External T.I. 9416315 - RETIRING ALLOWANCE,VESTED CONTRIBUTIONS

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.

28 July 1994 External T.I. 9414315 - RETIRING ALLOWANCE TRANSFER-DISCONTINOUS SERVICE

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 1994 External T.I. 9405865 - RETIRING ALLOWANCE - PERSON RELATED TO EMPLOYER

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 June 1993 T.I. (Tax Window, No. 32, p. 19, ¶2620)

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.

15 January 1993 T.I. (Tax Window, No. 28, p. 18, ¶2378)

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 March 1992 T.I. (Tax Window, No. 17, p. 19, ¶1784)

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 April 1992 T.I. (Tax Window, No. 18, p. 18, ¶1866)

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.

15 April 1992 T.I. (Tax Window, No. 18, p. 19, ¶1862)

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.

7 February 1992 Memorandum (Tax Window, No. 16, p. 14, ¶1737)

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 February 1992 T.I. (Tax Window, No. 16, p. 13, ¶1733)

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 1990 T.I. (Tax Window, Prelim. No. 1, p. 20, ¶1020)

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.

26 January 1990 T.I. (June 1990 Access Letter, ¶1261)

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-337R2 "Retiring Allowances" under "Tax Deferral"

IT-307R2 "Registered Retirement Savings Plan for Taxpayer's Spouse"

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 146 - Subsection 146(5.1) 0

ATR-8 "Transfer of Retiring Allowance to an RRSP"

Articles

Collins, "The Terminated Employee: Minimizing the Tax Bite", 1993 Conference Report, C. 31.

Subparagraph 60(j.1)(ii)(B)

Administrative Policy

29 February 2012 External T.I. 2011-0431131E5 F - Sommes versées en règlement d'un grief

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 5 - Subsection 5(1) damages on retroactive reinstatement are taxable 75
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(v) previous employment years of service included if bought back 145
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance damages for event occurring during employment generally will be non-taxable 204

Subparagraph 60(j.1)(v)

Administrative Policy

29 February 2012 External T.I. 2011-0431131E5 F - Sommes versées en règlement d'un grief

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 5 - Subsection 5(1) damages on retroactive reinstatement are taxable 75
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(ii)(B) employer contributions vest for each year bought back by an employee 121
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance damages for event occurring during employment generally will be non-taxable 204

Paragraph 60(l) - Transfer of refund of premiums under RRSP

Administrative Policy

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 5, 2017-0707801C6 F - RRIF transfers – partition of family patrimony

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 146.3 - Subsection 146.3(14) amount paid to surviving spouse's RRIF did not qualify under s. 146.3(14) 167
Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(1) - Designated Benefit payment from a deceased’s RRIF to the RRIF of the surviving spouse who was excluded under the will qualified as designated benefit 344

11 July 2016 External T.I. 2015-0592681E5 F - RRIF Death of an annuitant

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 146.3 - Subsection 146.3(1) - Annuitant surviving spouse who has been predesignated can qualify as an RRIF annuitant even if he or she does not receive any annuity payments 251
Tax Topics - Income Tax Act - Section 146.3 - Subsection 146.3(6.2) deduction for transfer to eligible recipient by surviving spouse 287
Tax Topics - Income Tax Act - Section 146 - Subsection 146(1) - Refund of Premiums consequence of death if named as beneficiary in RRSP contract 169

23 June 2014 External T.I. 2014-0528551E5 - Transfer of refund of premium

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.

11 January 2012 STEP Roundtable, 2011-0402291C6 - Subsection 248(8)-Intestacy-Transfer of Property

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.

19 June 1995 External T.I. 9515405 - 2 SPOUSES AS BENEFICIARIES OF RRSP

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. - Q.76

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.

Subparagraph 60(l)(ii)

Administrative Policy

23 January 2020 External T.I. 2019-0830781E5 - Charitable gift annuity and 60(l) rollover

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.

Subparagraph 60(l)(v)

Clause Subparagraph 60(l)(v)(B.01)

Administrative Policy

7 October 2011 Roundtable, 2011-0420781C6 F - Transfert de RPA à un REER au décès.

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 - 101-110 - Section 104 - Subsection 104(27) designation respecting RPP lump sum received by estate respecting disabled minor daughter and transferred to her RRSP 370
Tax Topics - Income Tax Regulations - Regulation 103 - Subsection 103(4) withholding required where RPP administrator pays RPP lump sum directly to RRSP of disabled minor daughter beneficiary of estate 335

Paragraph 60(n)

Subparagraph 60(n)(iv)

Administrative Policy

11 December 2009 Internal T.I. 2009-0350221I7 F - Prestations d'assurance emploi

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.

Subparagraph 60(n)(v.1)

Administrative Policy

18 June 2015 External T.I. 2015-0578071E5 F - Reimbursement of overpayment of QPIP 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.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 4 - Subsection 4(2) s. 60 deduction denied for repayment of previous income inclusion 138
Tax Topics - Other Legislation/Constitution - Federal - Financial Administration Act - Section 23 - Subsection 23(2) general criteria for granting remission 196

Paragraph 60(o) - Legal Expenses

See Also

Ridout v. The Queen, 2013 DTC 1209 [at 1115], 2013 TCC 260 (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.

Administrative Policy

21 January 2016 CPA Personal Income Tax Roundtable Q. 7, 2016-0625731C6 F - Fees related to a voluntary disclosure

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 20 - Subsection 20(1) - Paragraph 20(1)(cc) VDP fees deductible if re business 80

22 May 2014 Ponoka Liason Meeting Roundtable, 2014-0528451C6 - Cost of Making Voluntary Disclosure

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 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees costs of voluntary disclosure incurred by business 80
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) costs of voluntary disclosure incurred by business 80

17 October 2014 External T.I. 2014-0532121E5 F - Frais professionnels - Divulgation volontaire

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 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees voluntary disclosure fees generally non-deductible 133

25 April 2014 Internal T.I. 2014-0524191I7 - Deductibility of legal fees

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 December 2012 Internal T.I. 2012-0451331I7 F - Déductibilité de frais juridiques

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 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees legal expenses incurred to minimize responsibility under guarantee were not connected to operations which were necessary or incidental to the earning of income 220

5 June 2012 External T.I. 2012-0437831E5 - Professional Fees

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.

6 February 2012 External T.I. 2012-0434071E5 F - Honoraires professionnels - PDV

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 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees professional fees incurred in applying under the VDP are not deductible 177

26 August 1992 Memorandum 921728 (April 1993 Access Letter, p. 139, ¶C56-222)

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.

90 C.R. - Q15

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.

Subparagraph 60(o)(i)

Administrative Policy

11 October 2019 APFF Roundtable Q. 5, 2019-0812641C6 F - Professional fees incurred in the context of a litigation with CRA

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 60(o.1) - Idem [Legal Expenses]

Cases

Filion v. Canada, 2017 CAF 67

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

25 September 2014 External T.I. 2013-0500911E5 F - Legal Expense - Pension Benefit

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.

19 November 2012 Internal T.I. 2012-0433201I7 - Legal fees incurred re: job reinstatement

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.

26 September 1997 External T.I. 9723425 - ELIGIBLE AMOUNT, RESIDENCY

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.

24 March 1995 External T.I. 9424305 - LEGAL FEES

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.

22 July 1992 Internal T.I. 7-921394 -

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 60(t) - RCA distributions