Income Tax Severed Letters - 2024-12-31

Ruling

2024 Ruling 2024-1008821R3 F - Multi-wings split-up net asset butterfly 55(3)(b)

Unedited CRA Tags
55(2), 55(3)(b), 55(3.1), 80, 186(4), 187.1, 191.1, 245(2), 256(7)

Principal Issues: Whether the proposed transactions meet the requirements of paragraph 55(3)(b).

Position: Yes.

Reasons: Based on the Act, CRA publications and taxpayer's representations.

Technical Interpretation - External

29 August 2024 External T.I. 2024-1022841E5 - Indian Act Tax Exemption & Employment Income

Unedited CRA Tags
ITA para. 81(1)(a); IA s. 87

Principal Issues: Whether the employment income of a First Nations individual is situated on a reserve and exempt from income tax under section 87 of the Indian Act and paragraph 81(1)(a) of the Income Tax Act.

Position: Based on the information provided, no.

Reasons: Based on the information provided, none of the Indian Act Exemption for Employment Income Guidelines apply and the connecting factors identified by the Employee are not sufficient to situate the income on a reserve.