20

IT521R- Motor Vehicle Expenses Claimed by Self-Employed Individuals

NO.: IT-521R DATE: December 16, 1996 SUBJECT: INCOME TAX ACT Motor Vehicle Expenses Claimed by Self-Employed Individuals REFERENCE: Paragraph 18(1)(a) (also sections 67, 67.2, 67.3 and 67.4, subsections 13(2), 20(16.1), and the definitions of “passenger vehicle,” “automobile” and “motor vehicle” in subsection 248(1), and paragraphs 13(7)(g), 13(7)(h), 18(1)(h) and 85(1)(e.4) of the Income Tax Act; and section […]

IT521R- Motor Vehicle Expenses Claimed by Self-Employed Individuals Read More »

IT268R3- Inter vivos transfer of farm property to child

NO.: IT-268R3 DATE: February 13, 1987 SUBJECT: INCOME TAX ACT Inter Vivos Transfer of Farm Property to Child REFERENCE:  Subsections 73(3) and 73(4) (also sections 69, 75, 75.1, 80 and 110.6, subsections 40(1), 40(1.1), 70(9.6), 70(9.8), 70(10), 73(5), 100(2), 146(5.3), 146(5.4), 146(5.5), 248(1) and 252(1) and paragraphs 40(2)(b), 40(2)(c) and 54(g) of the Income Tax Act; subsections 20(1), 21(1), 21(2), 26(3), 26(5) and 26(19) of the Income Tax Application

IT268R3- Inter vivos transfer of farm property to child Read More »

Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations

Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations Series 4:  Businesses Folio 7:  Wind-ups, Dissolutions and Amalgamations Chapter 1:  Amalgamations of Canadian Corporations Summary This Chapter outlines the Canada Revenue Agency’s (CRA) views on a number of issues relating to the amalgamation of two or more taxable Canadian corporations as described in subsection 87(1) (referred to in this

Income Tax Folio S4-F7-C1, Amalgamations of Canadian Corporations Read More »

Income Tax Folio S4-F2-C1, Deductibility of Fines and Penalties

Income Tax Folio S4-F2-C1, Deductibility of Fines and Penalties Series 4: Businesses Folio 2: Deducting Business Expenses Chapter 1: Deductibility of Fines and Penalties Summary This Chapter discusses the deductibility of fines and penalties for income tax purposes. Several provisions of the Act deny the deduction of a fine or penalty. The key provision is section

Income Tax Folio S4-F2-C1, Deductibility of Fines and Penalties Read More »

Income Tax Folio S3-F2-C1, Capital Dividends

Income Tax Folio S3-F2-C1, Capital Dividends Series 3: Property, Investments and Savings Plans Folio 2: Dividends Chapter 1: Capital Dividends Summary This Chapter discusses capital dividends and the capital dividend account (CDA). The CDA keeps track of various tax-freesurpluses accumulated by a private corporation. These surpluses may be distributed tax-free in the form of capital dividends to the

Income Tax Folio S3-F2-C1, Capital Dividends Read More »

Income Tax Folio S3-F6-C1, Interest Deductibility

Income Tax Folio S3-F6-C1, Interest Deductibility Series 3: Property, Investments, and Savings Plans Folio 6: Interest Chapter 1: Interest Deductibility Summary The purpose of this Chapter is to explain the Canada Revenue Agency’s (CRA) position on the deductibility of interest expense under paragraph 20(1)(c). The Chapter also discusses various other provisions of the Act relating to interest deductibility. An amount

Income Tax Folio S3-F6-C1, Interest Deductibility Read More »

Income Tax Folio S3-F9-C1, Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime

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

Income Tax Folio S3-F9-C1, Lottery Winnings, Miscellaneous Receipts, and Income (and Losses) from Crime Read More »

TN-44-Exchangeable Debentures

Exchangeable Debentures: Paragraph 20(1)(f) Question 1 At the Canadian Tax Foundation’s 2008 annual conference,[Footnote 18] the CRA was asked to provide its views in respect of the application of paragraph 20(1)(f) to exchangeable debentures in light of the Federal Court of Appeal decision in Tembec Inc. et al. v. The Queen.[Footnote 19] The CRA was not prepared to comment at that

TN-44-Exchangeable Debentures Read More »

TN-41-Exchangeable Debentures

Exchangeable Debentures – Paragraph 20(1)(f) In Imperial Oil Ltd. v. Canada, 20 the Supreme Court of Canada held that paragraph 20(1)(f) does not apply to foreign currency losses. The CRA stated verbally at the 2006 Canadian Tax Foundation Annual Conference that commodity-based loans and exchangeable debenture financings currently in place would still be eligible for paragraph 20(1)(f) treatment. The

TN-41-Exchangeable Debentures Read More »

Scroll to Top
Scroll to Top