Single-Purpose Corporations The Canada Revenue Agency has recently completed the review of its administrative position not to assess a taxable benefit under subsection 15(1) of the Income Tax Act (the “Act”) where the taxpayer is the shareholder of a single-purpose corporation that has been established to hold U.S.-based real property. This position was first described in response […]
Income Tax Folio S2-F1-C1, Health and Welfare Trusts Series 2: Employers and Employees Folio 1: Specific Plans Offered by Employers to Employees Chapter 1: Health and Welfare Trusts Summary The purpose of this Chapter is to explain the position of the Canada Revenue Agency (CRA) concerning the taxation of certain employee health and welfare benefit programs
Income Tax Folio S2-F1-C1, Health and Welfare Trusts Read More »
Income Tax Folio S4-F3-C1, Price Adjustment Clauses Series 4: Businesses Folio 3: General Principles of Business Income Calculation Chapter 1: Price Adjustment Clauses Summary A price adjustment clause is typically incorporated into an agreement entered into by non-arm’s-length persons to provide for an adjustment to the transaction price in the event that a third-party such as
Income Tax Folio S4-F3-C1, Price Adjustment Clauses Read More »
Income Tax Folio S3-F9-C1, Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime Series 3: Property, Investments and Savings Plans Folio 9: Miscellaneous Payments/Receipts Chapter 1: Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime Summary This Chapter discusses the tax treatment of various receipts, such as strike pay, gambling winnings, and forfeited
NO.: IT-529 DATE: February 20, 1998 SUBJECT: INCOME TAX ACT Flexible Employee Benefit Programs REFERENCE: Paragraph 6(1)(a) (also subsections 6(3), 6(4), 15(1); the definitions of “salary deferral arrangement,” “retirement compensation arrangement,” “group term life insurance policy” and “private health services plan” in subsection 248(1); paragraphs 6(1)(f), 6(1)(g), 6(1)(h), 6(1)(i), subparagraphs 56(1)(a)(i) and (iii)) Application This bulletin discusses various tax consequences that may
IT-63R5 DATE: AUGUST 21, 1995 SUBJECT: INCOME TAX ACT Benefits, Including Standby Charge for an Automobile, from the Personal Use of a Motor Vehicle Supplied by an Employer – after 1992 REFERENCE: Paragraphs 6(1)(a), (e), (e.1), (k) and (l) and subsections 6(1.1), (2), (2.1), and (7) (also subsections 15(1), (1.3), (1.4), (5) and (7) and
NO: IT-357R2 DATE: November 6, 1989 SUBJECT: INCOME TAX ACT Expenses of Training REFERENCE: Subsection 18(1) (also section 67, subsections 15(1) and 20(10), and paragraph 6(1)(a)) Application This bulletin replaces and cancels Interpretation Bulletin IT-357R dated May 21, 1980. Current revisions are indicated by vertical lines. Summary This bulletin deals with the deductibility of costs and
NO: IT-119R4 DATE: August 7, 1998 SUBJECT: INCOME TAX ACT Debts of Shareholders and Certain Persons Connected With Shareholders REFERENCE: Subsection 15(2) (also subsections 15(1), 15(1.2), 15(2.1) to (2.7), 15(7), 15(9), 212(2), 214(3) and 227(6.1), 248(1) definitions of “foreign affiliate” and “specified employee” and paragraph 20(1)(j)) Application This bulletin cancels and replaces Interpretation Bulletin IT-119R3, dated
IT119R4- Debts of Shareholders and Certain Persons Connected With Shareholders. Read More »
NO: IT-116R3 DATE: February 28, 1995 SUBJECT: INCOME TAX ACT Rights to Buy Additional Shares REFERENCE: Paragraph 15(1)(c) (also definition of “share”, “common share” and “shareholder” in subsection 248(1)) Application This bulletin replaces and cancels Interpretation Bulletin IT-116R2 dated January 12, 1990 and applies to benefits conferred after December 19, 1991. Summary This bulletin deals with
NO.: IT-432R2 DATE: February 10, 1995 SUBJECT: INCOME TAX ACT Benefits Conferred on Shareholders REFERENCE: Subsection 15(1) (also sections 84 and 246; subsections 15(1.1) to 15(1.4), 15(7), 52(1), 52(1.1), 56(2) and 248(1) definitions of “property”, “corporation”, “shareholder” and “specified shareholder”; paragraphs 6(1)(a), 69(1)(b), 82(1)(a) and 214(3)(a); and subparagraph 129(1)(a)(i) of the Income Tax Act; and