Section 67.3

Administrative Policy

2 April 2014 External T.I. 2012-0473151E5 F - Limitation du coût de location d'un véhicule

Are amounts of recovered GST and QST respecting the lease of a vehicle to be considered in element E in ss. 67.3(c) and (d)? CRA responded:

Most...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(16) GST ITCs constitute a “reimbursement” for car lease expense limitation purposes 162

22 May 1990 T.I. (October 1990 Access Letter, ¶1465)

The amount based on the manufacturer's list price is not reduced by employee deposits or by depreciation due to the age of the vehicle, and...

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23 April 1990 T.I. (September 1990 Access Letter, ¶1418)

"Amounts deducted" refers to the portion of the expense that was laid out to earn income.

18 October 89 Meeting with Quebec Accountants, Q.9 (April 90 Access Letter, ¶1166)

Where a corporation leases a fleet of vehicles, and subleases them to other members of the corporate group, s. 67.3 could apply both to it and to...

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88 C.R. - "Automobile Rules" - "With Respect to Expensive Automobiles"

S.67.3 applies to lump sums paid at the beginning or end of the lease.

Articles

Summerville, "Car Options Can Be Paid by Employees in Order to Avoid Leasing Limitations", Taxation of Executive Compensation and Retirement, October 1990, p. 347.