Income Tax Severed Letters - 2022-11-30

Ruling

2022 Ruling 2022-0930901R3 F - Changes to an existing monetization arrangement

Unedited CRA Tags
80.6
Summary Under
Tax Topics - Income Tax Act - Section 80.6
partial acceleration of a forward contract did not de-grandfather it from the synthetic disposition rules

Principal Issues: Whether changes in monetization arrangements entered into in XXXXXXXXXX to provide for the right to accelerate the maturity date under the forward contract in respect of part of the reference shares would trigger the application of section 80.6.

Position: No.

Reasons: According to the law.

Ministerial Correspondence

18 July 2022 Ministerial Correspondence 2022-0940661M4 - Tax status of income earned by employees

Unedited CRA Tags
81(1)(a) of the ITA, Section 2 and 87(1)(b) of the Indian Act

Principal Issues: Whether employment income of an employee qualifies for an exemption from income tax under section 87 of the Indian Act because the employee is registered under the Act and the employer is located on Indigenous territory.

Position: No.

Reasons: The Indigenous territory that the employer is located on does not meet the definition of a reserve under the Indian Act, the employment income that the employee receives from the employer does not qualify for an exemption from income tax.

Technical Interpretation - Internal

19 May 2022 Internal T.I. 2022-0936461I7 - Relief measure program

Unedited CRA Tags
56(1)(u), ITR 233(1), ITR 233(2)

Principal Issues: What is the tax treatment of payments to individuals, under the Government of XXXXXXXXXX potential relief measure program?

Position: Likely included in the recipients income under paragraph 56(1)(u) with an offsetting deduction from taxable income, pursuant to paragraph 110(1)(f).