Income Tax Severed Letters

This Week's Release

Ruling

2019 Ruling 2018-0761621R3 - Cross-Border Butterfly

Unedited CRA Tags
55(2), 55(3)(b), 55(3.1), 55(3.2)(h), 212.1(1), 212.1(1.1), 212.1(1.2)

Principal Issues: Whether the Canadian Butterfly Transactions, as described below, in the context of a cross-border butterfly, meet legislative and administrative requirements?

Position: Transactions meet requirements.

Reasons: Consistent with law and administrative requirements.

Technical Interpretation - Internal

8 May 2009 Internal T.I. 2009-0309401I7 - Incurring debts to make gifts to qualified donees

Unedited CRA Tags
149.1(4)(d) 149.1(4)(b) proposed 149.1(4)(b.1)

Principal Issues: Can a private foundation borrow to make gifts to qualified donees?

Position: No.

Reasons: 149.1(4)(d). Gifts made in charitable activities carried on by a private foundation are mutually exclusive from gifts made to qualified donees.

Archive

2020
April
March
February
January
2019
December
November
October
September
August
June
April
March
February
January
2018
December
November
October
September
June
April
March
February
January
2017
December
November
October
September
June
April
February
January
2016
December
November
October
September
August
July
May
April
February
January
2015
December
November
October
September
August
July
April
March
February
January
2014
December
November
October
September
August
July
June
May
April
March
February
January
2013
December
November
October
September
August
July
June
April
March
February
January
2012
December
November
October
September
August
July
May
April
March
February
January
2011
December
November
October
September
August
July
June
May
April
March
February
January
2010
December
November
October
September
August
July
June
May
April
March
February
January
2009
December
November
October
September
August
July
June
April
March
February
January
2008
December
November
October
September
August
July
June
May
April
March
February
January
2007
December
November
October
September
August
July
June
May
April
March
February
January
2006
December
November
October
September
August
July
June
May
April
March
February
January
2005
December
November
October
September
August
July
June
May
April
March
February
January
2004
December
November
October
September
August
July
June
May
April
March
February
January
2003
December
November
October
September
August
July
June
May
April
March
February
January
2002
December
November
October
September
August
July
June
May
April
March
February
January
2002-01-18 (96)
2002-01-04 (103)
2001
December
November
October
September
August
July
June
May
April
2001-04-27 (74)
2001-04-13 (106)
March
February
January
2000
December
November
October
September
August
July
June
May
April
March
February
January
1999
December
November
October
September
August
July
June
May
April
March
February
January
1999-01-22 (134)
1999-01-08 (89)
1998
December
November
1998-11-27 (72)
1998-11-13 (106)
October
September
August
July
June
May
1998-05-29 (105)
1998-05-15 (62)
1998-05-01 (49)
April
March
February
January
1997
December
November
October
September
1997-09-19 (63)
1997-09-05 (185)
August
July
June
1997-06-27 (54)
1997-06-13 (181)
May
April
March
February
January
1996
December
November
October
September
August
July
June
May
April
March
February
January
1995
December
November
October
September
August
July
June
May
April
March
February
January
1994
December
November
October
September
August
July
June
May
April
March
February
January
1993
December
November
October
September
August
July
June
1993-06-18 (104)
1993-06-04 (76)
May
April