| 2018-05-02 |
9 April 2018 External T.I. 2017-0714381E5 F - Application de l'article 67.1 |
Income Tax Act - Section 67.1 - Subsection 67.1(1) |
hockey game tickets purchased by a hockey player recruiter are subject to s. 67.1 |
| 9 April 2018 Internal T.I. 2017-0731251I7 F - Activités mondaines |
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) |
computation of the $150 cost per employee safe harbour for employee parties |
| 2018-04-11 |
6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 8, 2017-0712621C6 F - Dépôt en monnaie étrangère-Immobilisation |
Income Tax Act - Section 70 - Subsection 70(5) |
FX deposit treated as debt rather than s. 39(1.1) currency |
| Income Tax Act - Section 39 - Subsection 39(1.1) |
non-application to FX deposits |
| 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 9, 2017-0705231C6 F - Gift of a Life Insurance Policy and Subrogated Own |
Income Tax Act - Section 148 - Subsection 148(7) - Paragraph 148(7)(a) |
gain by estate on gift of policy based on cash surrender value |
| Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts - Paragraph (c) - Subparagraph (c)(i) - Clause (c)(i)(C) |
claim in terminal return for charitable gift made by estate under individual’s will |
| Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts - Paragraph (c) - Subparagraph (c)(i) - Clause (c)(i)(A) |
no guidance on whether designating a charity as a contingent policyholder generates a charitable credit |
| 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 10, 2017-0705201C6 F - Capital loss - repayment of loan |
Income Tax Act - Section 40 - Subsection 40(3.3) |
the foreign currency deemed to be disposed of under s. 39(2) by an FX borrower on repaying a USD loan is not identical property to the USDs received by it under a replacement loan |
| Income Tax Act - Section 248 - Subsection 248(1) - Property |
foreign currency is not property for purposes of the suspended-loss rules |
| 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 14, 2017-0708511C6 F - T1135 and 162(7) penalty |
Income Tax Act - Section 162 - Subsection 162(7) |
penalty for late-filing of a T1135 will be imposed automatically |
| Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) |
failure to file a T1135 treated as a misrepresentation – but neglect etc. ground to be determined |
| 6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 16, 2017-0705181C6 F - Hedging & George Weston Limited |
Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges |
CRA is considering changing its policy re what is capital hedge |
| 2013-10-02 |
6 May 2009 External T.I. 2008-0295581E5 F - Bourses et aide financière aux médecins |
Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) |
specialized training grants made to unlicensed medical residents to encourage them to settle in remote areas were s. 56(1)(n) fellowships |
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) |
s. 12(1)(x) inclusion of assistance to foreign doctors to become licensed so that they will practise in a remote area |
| 4 September 2013 External T.I. 2013-0490631E5 F - Éoliennes d'Essai |
Income Tax Regulations - Regulation 1219 - Subsection 1219(3) |
opinion on test wind turbines installed on wind farm |
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