| 2022-07-13 |
10 February 2022 External T.I. 2021-0912581E5 F - Borrowing to make interest-free loans |
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) |
interest-free loans by a limited partner to the LP, or to wholly-owned subs which directly or indirectly hold such LP, can be a good s. 20(1)(c)(i) current use |
| 2004-08-20 |
29 July 2004 Internal T.I. 2003-0023761I7 F - Contrat de SWAP d'équité |
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss |
loss on equity swap entered into in monetization transaction was on capital accountexcerpted in 2009-0323991I7 F |
| Income Tax Act - Section 248 - Subsection 248(1) - Disposition |
termination of equity swap contract entailed the disposition of propertyexcerpted in 2009-0323991I7 F |
| Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) |
swap termination payment could be deducted if it was incurred to make the disposition (the swap payment termination)excerpted in 2009-0323991I7 F |
| Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges |
equity swap was to hedge the risk under a capital borrowing, so that loss on closing out the swap was on capital accountexcerpted in 2009-0323991I7 F |
| 29 July 2004 Internal T.I. 2004-0065971I7 F - Frais d'intégration de sociétés |
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Current expense vs. capital acquisition |
costs of integrating targets that were on-charged to them after closing were currently deductible to parent |
| 3 August 2004 Internal T.I. 2004-0077991I7 F - Allocations d'aide à domicile reçues de la SAAQ |
Income Tax Act - Section 3 - Paragraph 3(a) |
insurance proceeds to compensate for parent’s home care services provided to disabled son were non-taxable |
| Income Tax Act - Section 152 - Subsection 152(1) |
CRA applies changes to its position as a result of taxpayer-friendly judgments effective to post-judgment assessments |
| 2004-08-13 |
12 July 2004 Internal T.I. 2004-0077981I7 F - Dédommagement-Régime de pension |
Income Tax Act - Section 3 - Paragraph 3(a) |
lump sum settlement of pension claim was non-taxable |
| 2004-08-06 |
27 July 2004 External T.I. 2004-0077581E5 F - Transfert d'un REÉR à une fiducie |
Income Tax Act - Section 146 - Subsection 146(2) - Paragraph 146(2)(b.4) |
qualifying RRSP cannot have a trust as the annuitant |
| Income Tax Act - Section 146 - Subsection 146(12) |
transfer by an individual of his RRSP to a trust set up for his exclusive benefit would engage s. 146(12)(b) |
| Income Tax Act - Section 146 - Subsection 146(1) - Retirement Savings Plan |
listing of qualified issuers |
| 30 July 2004 External T.I. 2004-0063811E5 F - Soutien administratif à une filiale |
Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) - Subparagraph 37(8)(a)(ii) - Clause 37(8)(a)(ii)(A) |
parent can use traditional method while subsidiary uses proxy method |
| Income Tax Act - Section 37 - Subsection 37(13) |
administrative support tasks of the parent respecting SR&ED activities of its subsidiary would not be considered SR&ED of the parent |
| 3 August 2004 External T.I. 2004-0066431E5 F - Contrat de rente et fiducie |
Income Tax Act - Section 75 - Subsection 75(2) |
"by a trust" includes any transaction performed by the trustees |
| 30 July 2004 External T.I. 2004-0083841E5 F - Développement informatique |
Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A |
whether an interest in software has been acquired is determined under common or civil law |
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