Principal Issues: Whether a lossco will be entitled to apply its non-capital losses against the interest income generated as part of the loss consolidation transactions and whether profitcos will be entitled to deduct the corresponding interest expense.
Position: Yes.
Reasons: Conforms to our requirements for such rulings.
alter ego trust is entitled to a deduction for ordinary income distributions in the year of death
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Principal Issues: For taxation years ending after 2015, in the year that the primary beneficiary of an alter ego trust dies, can the trust claim a deduction in respect of the income earned by the trust and which became payable to that beneficiary prior to their death?
Position: A deduction may be claimed in respect of amounts which became payable to the primary beneficiary prior to their death; however, no deduction is available in respect of capital gains and other amounts recognized by the trust upon the death of the beneficiary pursuant to subsections 104(4) to 104(5.2) (the “deemed disposition rules”) and subsection 12(10.2).
Reasons: Element B of the formula in paragraph 104(6)(b).
Principal Issues: Whether ITRD will provide a technical interpretation to a taxpayer where the issue is under audit.
Position: No.
Reasons: Paragraph 7(c) of IC 70-6R7 explains that a technical interpretation will not be issued to a taxpayer where the request relates to a matter that is under audit.
Principal Issues: Is the cost of prescription swimming goggles an eligible medical expense for the purpose of the medical expense tax credit?
Position: Yes, if the swimming goggles are prescribed by a medical practitioner or optometrist specifically for the treatment or correction of a specified defect of vision.
Principal Issues: Whether section 19.1 applies to deny a deduction for expenses to be incurred by a Canadian taxpayer to advertise on a foreign internet website.
