Income Tax Severed Letters - 2025-06-25

Ruling

2024 Ruling 2023-0999251R3 - Post-mortem pipeline

Unedited CRA Tags
84.1, 84(2), 212.1(6)

Principal Issues: 1. Does paragraph 84.1(1) apply to reduce the PUC in the Proposed Transactions? 2. Does subsection 84(2) apply to the Proposed Transactions? 3. Does the GAAR apply to the Proposed Transactions?

Position: Positive rulings provided on the non-application of section 84.1 and subsection 84(2) and GAAR.

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

Technical Interpretation - External

16 May 2025 External T.I. 2025-1055731E5 - Life insurance – return of premiums

Unedited CRA Tags
56(1)(j), 148(1), 148(9), Reg 308

Principal Issues: We were asked to provide comments on the taxation of a return of premium amount received by a policyholder from a life insurance company upon the maturity of a term life insurance policy.

Position: General comments provided.

Reasons: Legislation.

6 May 2025 External T.I. 2024-1031071E5 - Subparagraph 149(5)(e)(ii) and vacant land

Unedited CRA Tags
149(1)(l); 149(2); 149(5)

Principal Issues: Would a parcel of land that was only used by a golf club as a golf range for a limited period of time during its ownership be considered “property used exclusively for and directly in the course of providing the dining, recreational or sporting facilities provided” by the golf club for the purposes of subparagraph 149(5)(e)(ii) of the Income Tax Act?

Position: No, the land was not “property used exclusively for and directly in the course of providing the dining, recreational or sporting facilities provided” by the golf club for its members.

Reasons: See response.