Principal Issues: Whether Lossco would be entitled to apply existing non-capital losses against the interest income that would be generated as part of particular loan that would be made under the loss consolidation transaction and whether the accompanying interest expense would be deductible by Profitco.
Position: Yes.
Reasons: The proposed transactions conform to our requirements for these types of loss consolidation rulings. The proposed transactions would be legally effective and commercially realistic.
Subsection 118.2(2), Section 5700 of the Regulations
Principal Issues: Whether the costs incurred for: 1) Proloquo2Go software; 2) an Apple iPad; and 3) a Liftware spoon qualify as medical expenses for purposes of the Medical Expense Tax Credit.
Position: 1) Likely yes; 2) No; 3) No.
Reasons: 1) The Proloquo2Go software appears to be similar to a bliss symbol board as described in Income Tax Regulation 5700(x); 2) An Apple iPad does not meet the requirements under subsection 118.2(2); 3) The Liftware spoon does not meet the requirements under subsection 118.2(2).
