Principal Issues: How does the Tsiaprailis decision impact the CRA's position in respect of the deductibility and requirement for income inclusion of a lump sum support payment?
Position: The Tsiaprailis decision does not change our position in respect of a lump sum support payment.
Reasons: The CRA's position with respect to this issue is set out in paragraphs 21 and 22 of Interpretation Bulletin IT-530R.
2005-0139731C6
Power, Karen
July 12, 2005
Institute of Chartered Accountants of Alberta Round Table Question:
Question 11 (d):
How does the Supreme Court of Canada decision in Tsiaprailis impact the CRA's position in respect of the deductibility and the requirement for income inclusion of a lump sum support payment?
Response:
The Tsiaprailis decision does not change our position in respect of the deductibility and the requirement for income inclusion of a lump sum support payment. The CRA's position with respect to this issue is set out in paragraphs 21 and 22 of Interpretation Bulletin IT-530R.