Income Tax Severed Letters - 2025-06-11

Ruling

2024 Ruling 2024-1043951R3 - Post-Mortem Pipeline - Supplemental Ruling

Unedited CRA Tags
84(2); 84.1

Principal Issues: Whether correction to ruling request impacts rulings provided.

Position: No.

Reasons: Correction relates solely to a misdescription of share terms that do not impact the outcome of the proposed transactions.

Technical Interpretation - External

24 April 2025 External T.I. 2024-1045691E5 - DST - Online Marketplace and User definitions

Unedited CRA Tags
section 2 definitions of DSTA

Principal Issues: Based on the hypothetical facts provided, whether suppliers who provide digital content to a digital interface are "users" of the digital interface and whether that digital interface is an "online marketplace".

Position: Yes, the suppliers are users of the digital interface and the digital interface is an online marketplace in the context of the hypothetical facts.

Reasons: Based on the text of the "online marketplace" and "user" definitions, the meaning of “interact” and the policy intent of the "online marketplace" definition, the suppliers interact with the digital interface as well as with other users of the digital interface.

25 March 2025 External T.I. 2024-1039131E5 - CCUS - "actual eligible use percentage"

Unedited CRA Tags
127.44(1)"eligible use", "ineligible use" and "projected eligible use percentage", 127.44(15), 211.92(1)"actual eligible use percentage"

Principal Issues: In determining "actual eligible use percentage" under subsection 211.92(1) of a CCUS project, is the quantity of captured carbon that the CCUS project supports for storage or use in eligible use and ineligible use determined with reference to measurements of captured carbon within the boundaries of the particular project or with reference to measurements of captured carbon from locations upstream or downstream of the particular project?

Position: The actual eligible use percentage of a CCUS project is determined by reference to measurements of the end use of the captured carbon, irrespective of the particular project boundaries.

Reasons: Textual, contextual, and purposive analysis of the relevant provisions.

1 October 2024 External T.I. 2023-0995461E5 - Mineral Resource Certificate

Unedited CRA Tags
Definition of "mineral resource" in subsection 248(1)

Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the lithium-bearing spodumene deposits on the property will be an industrial mineral extracted from a non-bedded deposit.

Position: Yes.

Reasons: Positive Opinion provided by NRCan.