Income Tax Severed Letters - 2006-08-04

Technical Interpretation - External

17 July 2005 External T.I. 2005-0155601E5 - Life estate, principal residence

Unedited CRA Tags
43.1 54

Principal Issues: Consequences to taxpayer as a result of the transfer of remainder interest in her mother's principal residence to her

Position: General comments given regarding the application of section 43.1

Reasons: The law

Conference

9 May 2006 Roundtable, 2006-0174131C6 - Small business deduction active business assets

Unedited CRA Tags
248(1)

Principal Issues: Is a corporation's refundable dividend tax on hand an asset that is used principally in an active business carried on in Canada for purposes of the definition of "small business corporation" in subsection 248(1) of the Income Tax Act?

Position: No

Reasons: Previous position taken