Income Tax Severed Letters

This Week's Release

Ruling

2019 Ruling 2019-0791661R3 - 55(3)(a) Reorganization

Unedited CRA Tags
55(3)(a)

Principal Issues: Whether the reorganization meets the requirements of paragraph 55(3)(a).

Position: Yes.

Reasons: Meets legislative requirements.

Technical Interpretation - External

9 August 2019 External T.I. 2019-0813021E5 - TOSI and excluded shares

Unedited CRA Tags
120.4(1); 120.4(1.1)
a corporate partner carries on the business of the partnership for TOSI (and other) purposes
partner carries on business of partnership

Principal Issues: 1. Whether the shares held by specified individuals in the capital stock of corporations that are members of a partnership will constitute excluded shares? 2. Would the answer in 1) change if the specified individuals were related?

Position: 1. Yes; 2. No.

Reasons: See comments.

30 July 2019 External T.I. 2019-0807521E5 - PEMF - pulsed electromagnetic therapy

Unedited CRA Tags
118.2(2)(a); 118.4(2)

Principal Issues: Whether in a particular situation, treatments using pulsed electromagnetic fields (EPMF) may be considered "medical services" that are eligible for the purpose of the medical expense tax credit (METC).

Position: Question of fact, depending on whether PEMF therapy is a) provided by a medical practitioner who is authorized by their respective provincial or territorial jurisdiction to provide such therapy/treatments; and b) obtained to treat an existing illness or medical condition.

Reasons: Paragraph 118.2(2)(a) of the Act, which requires that medical services be provided by a medical practitioner within the meaning of subsection 118.4(2); and previous interpretations that payments to medical practitioners are considered eligible medical expenses if paid for medical services that relate to existing illnesses or conditions.

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