| 2021-09-01 |
21 June 2021 External T.I. 2019-0815871E5 F - 83(2)b) and cost |
Income Tax Act - Section 54 - Adjusted Cost Base |
promissory note issued in satisfaction of a capital dividend has full cost |
| Income Tax Act - Section 52 - Subsection 52(1) |
s. 52(1) is unnecessary to establishing full cost for a note transferred in satisfaction of a capital dividend |
| 2007-02-09 |
17 January 2007 Internal T.I. 2006-0216331I7 F - Association |
Income Tax Act - Section 256 - Subsection 256(2) |
administrative policy regarding late elections by third corporation |
| 2007-01-26 |
6 October 2006 Roundtable, 2006-0197031C6 F - Obligation achetée à prime |
Income Tax Act - Section 54 - Adjusted Cost Base |
premium paid on secondary purchase of bond is part of bond ACB |
| Income Tax Act - Section 12 - Subsection 12(9.1) |
purchase of bond at a premium does not engage s. 12(9.1) |
| Income Tax Regulations - Regulation 7000 - Subsection 7000(1) - Paragraph 7000(1)(b) |
bond that was purchased at a premium is not a Reg. 7000(1)(b) obligation |
| 6 October 2006 Roundtable, 2006-0197091C6 F - Sens de série de paiements périodiques |
Income Tax Act - Section 60.01 |
successive partial IRA surrenders are excluded as “a series of periodic payments” |
| 19 January 2007 Internal T.I. 2006-0216451I7 F - Fondation privée investissant dans une S.P. |
Income Tax Act - Section 96 |
separate legal personality of DRUPA (or DRULPA) partnerships does not preclude them from being partnerships |
| Income Tax Act - Section 149.1 - Subsection 149.1(4) - Paragraph 149.1(4)(a) |
foundation’s registration subject to revocation because it had invested in a Delaware partnership (with stated separate existence) carrying on business |
| 2007-01-19 |
10 January 2007 External T.I. 2006-0171132E5 F - Revenu locatif |
Income Tax Act - Section 54 - Principal Residence - Paragraph (a) |
exemption potentially available re bungalow rented (but not as a source of income) to daughter |
| Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit |
house rented to daughter at below-market rent was not a source of income – rents excluded form income |
| 16 January 2007 External T.I. 2006-0217641E5 F - Dépenses de vêtements - travailleur indépendant |
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) |
clothing expenses of personal stylist are non-deductible |
| 17 January 2007 External T.I. 2005-0152601E5 F - Politique d'application RS & DE 1996-02 |
Income Tax Act - Section 37 - Subsection 37(1) - Paragraph 37(1)(a) |
LGL and Tigney pro rata approach to in-Canada requirement |
| 2007-01-12 |
5 January 2007 External T.I. 2005-0133321E5 F - Validité d'un REER |
Income Tax Act - Section 248 - Subsection 248(3) - Paragraph 248(3)(c) |
RRSP arrangement that was not a civil law trust was cured by s. 248(3)(c) |
| 3 January 2007 External T.I. 2006-0180601E5 F - Facturation entre deux sociétés affiliées. |
Income Tax Act - Section 230 - Subsection 230(1) |
invoices between domestic affiliates not required, but should be retained for evidentiary purposes consistently with IC-78-10R4 |
| General Concepts - Evidence |
invoices between domestic affiliates are not required, but are recommended |
| 15 December 2006 External T.I. 2006-0182471E5 F - Intérêts " explicitement identifiés " |
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) |
whether a court order or settlement “explicitly identifies” pre-judgment interest, so as to be taxable, is question of fact |
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