Income Tax Severed Letters - 2019-10-16


2019 Ruling 2018-0754531R3 F - Post-mortem planning - Pipeline

Unedited CRA Tags
84.1, 84(2), 245(2)

Principales Questions: Post-mortem planning

Position Adoptée: Favourable rulings provided

Raisons: See below

Technical Interpretation - External

10 September 2019 External T.I. 2019-0801361E5 - Tuition expenses

Unedited CRA Tags

Principal Issues: Whether various fees paid by medical students are eligible for the tuition tax credit.

Position: Likely not.

Reasons: In most cases the fees are not paid to an educational institution. Application fees to attend a medical school in which the medical student subsequently enrolls may be eligible.

15 August 2019 External T.I. 2018-0749261E5 - Stabilization Reserves

Unedited CRA Tags
6(1)(a)(i); 248(1) “private health services plan”

Principal Issues: Whether a stabilization reserve within a health and dental program may disqualify the plan as a private health services plan (“PHSP”).

Position: See response.

Reasons: See response.

Technical Interpretation - Internal

15 May 2019 Internal T.I. 2019-0803411I7 - Medical practitioners - the METC & the DTC

Unedited CRA Tags
118.4(2); 118.3(a.2) and 118.3(a.3)

Principal Issues: Whether the CRA can set up a process to consider requests to change (or expand) the categories of medical practitioners who can certify Form T2201, Disability Tax Credit Certificate.

Position: No.

Reasons: Changes to the categories of medical practitioners who can provide certification for the purpose of the disability tax credit (DTC) would require a legislative amendment to section 118.3 – this is beyond the CRA's mandate as an administrator of the Act.