Income Tax Severed Letters - 2005-09-23


2005 Ruling 2005-0130541R3 - Participating Interest

Unedited CRA Tags

Principal Issues: Can the Additional Interest paid or payable be deducted under paragraph 20(1)(c) provided it does not exceed a reasonable amount?

Position: YES

Reasons: IT-533, par 2 - not an equity investment.

Technical Interpretation - External

20 September 2005 External T.I. 2005-0145331E5 - Disposition -Interest in a Life Insurance Policy

Principal Issues: The taxpayer required clarification on whether the calculation of a gain on the disposition of a policy with a "return of premium" benefit is correct.

Position: Appears correct.

Reasons: Our review of relevant provisions and information provided by the insurer and taxpayer.