Income Tax Severed Letters - 2024-12-24

Ruling

2022 Ruling 2022-0930051R3 - Supplemental ruling

Unedited CRA Tags
Paragraph 55(3)(b), subsection 55(2)

Principal Issues: Supplemental ruling to 2020-084806 Whether minor typographical and factual corrections affect the butterfly ruling previously issued?

Reasons: The changes do not impact the butterfly already completed.

Technical Interpretation - External

26 July 2024 External T.I. 2024-1019091E5 - XXXXXXXXXX Employment Incentive (XXXXXXXXXX) Program

Unedited CRA Tags
56(1)(r), 56(1)(u), ITR 233(1), ITR 233(2)

Principal Issues: What is the tax treatment of monthly benefit payments to families under the XXXXXXXXXX Employment Incentive (XXXXXXXXXX) program and how to report it?

Position: Likely included in the recipients income under paragraph 56(1)(u) with an offsetting deduction from taxable income, pursuant to paragraph 110(1)(f). They will be required to be reported on T5007.

Reasons: Assistance appears to be a social assistance made on the basis of a means, needs or income test.

Technical Interpretation - Internal

9 July 2024 Internal T.I. 2023-0976691I7 - Film Tax Credit and Alter Ego Trust

Unedited CRA Tags
125.4, 125.5, 1(1) BC ITA, 2(1) BC ITA, 79(1) BC ITA

Principal Issues: For purposes of the BC Film Tax Credit, do the shares held in an alter ego trust "belong to" the trust or to the trustee, who is also the settlor?

Position: Based on the facts provided, they belong to the trustee.

Reasons: See memo.