Income Tax Severed Letters - 2020-07-15

Ruling

2020 Ruling 2020-0839401R3 - Post-mortem Pipeline

Unedited CRA Tags
84.1, 84(2), 245

Principal Issues: 1. Does paragraph 84.1(1)(b) deem a dividend in the Proposed Transactions? 2. Does subsection 84(2) apply to the Proposed Transactions? 3. Does the GAAR apply to the Proposed Transactions?

Position: 1. No. Favourable Rulings Given. 2. No. Favourable Rulings Given. 3. No. Favourable Rulings Given.

Reasons: The Proposed Transactions are in accordance with the Act, relevant jurisprudence and are consistent with our previous positions.

Technical Interpretation - External

12 June 2020 External T.I. 2018-0788161E5 F - Adjusted stub period accrual amount

Unedited CRA Tags
34.2, 34.3, 53(1)e), 53(2)c), 96(1)d), 96(2.1), 96(2.2), 96(2.4), 111(1)e)
Summary Under
Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(1) - Adjusted Stub Period Accrual Income - Paragraph (a) - Element B
ASPA not reduced by s. 111(1)(e) losses

Principales Questions: Whether limited partnership losses should be considered in the calculation of the adjusted stub period accrual amount under section 34.2.

Position Adoptée: No.

Raisons: Application of the Act.

8 May 2020 External T.I. 2019-0829901E5 - Deductibility of child care expenses

Unedited CRA Tags
ITA: 63(1)(d)

Principal Issues: Whether a taxpayer is required to reduce the amount of child care expenses that they would otherwise claim under section 63 by the amount that the taxpayer is entitled to receive as a reimbursement from the other parent, despite the fact the taxpayer did not receive the amount owing.

Position: Yes.

Reasons: See response.