Words and Phrases - "Crown agent"
21 June 2004 External T.I. 2004-0074851E5 F - Allocation de retraite
Summary Under
Tax Topics - Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(c) - Subparagraph 251(2)(c)(i)two municipalities were not Crown agents or controlled by provincial government and, therefore, were not related
Whether severance that became payable to the taxpayer was a retiring allowance turned on whether the municipality who terminated her was related...
Words and Phrases
Crown agentLocations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | severance was a retiring allowance even though the employee was hired by another municipality that had agreed to take over the municipal functions of her first employer | 366 |
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(ii) - Clause 60(j.1)(ii)(C) | unrelated person who has assumed a severance payment obligation is treated as paying the severance on behalf of the “employer” who terminated | 180 |