Income Tax Severed Letters - 2026-08-19

Ruling

2024 Ruling 2024-1015641R3 - Loss Consolidation Arrangement

Unedited CRA Tags
12(1)(x), 18.2(1), 18.2(4), 18.2(9), 20(1)(c), 55(2), 88(1.1), 111, 112(1), 112(2.1), 112(2.2), 112(2.3), 112(2.4), 123.6, 245(2)

Principal Issues: Whether the loss consolidation arrangement is acceptable.

Position: Yes.

Reasons: The proposed transactions conform to our requirements for these types of loss consolidation rulings. The proposed transactions would be legally effective and commercially plausible.

Technical Interpretation - External

1 June 2026 External T.I. 2023-1001921E5 - Registered Plan Secured Loan - Advantage

Unedited CRA Tags
LEGISLATIVE REFERENCE: 207.01(1)
the advantage rules apply where in substance annuitants have transferred employment income to their RRSP under a mortgage loan by it to them
mortgage loan by RRSP to controlling individual could engage (b)(i) of “advantage”

Principal Issues: Whether a loan from a registered plan secured by real property is an advantage pursuant to subparagraph (b)(ii) of the definition of the word in subsection 207.01(1).

Position: Question of fact.

Reasons: Question of fact.

5 May 2026 External T.I. 2025-1055171E5 - Employer Contributions - Health Care Spending Account

Unedited CRA Tags
5(1); 6(1)(a)(i); 56(2)

Principal Issues: Whether payments made by the Retirement Benefit Program Fund to a health care spending account are "employer contributions" to the plan, as contemplated by subparagraph 6(1)(a)(i) of the Income Tax Act, or foregone income of active employees.

Position: Question of fact and law.

Reasons: Tax treatment depends on whether the employer had a legal obligation to make contributions on its own accord.

28 April 2026 External T.I. 2026-1088091E5 - Mineral Resource Certification

Unedited CRA Tags
248(1) "mineral resource"

Principal Issues: Whether a deposit qualifies as a mineral resource as that term is defined in subsection 248(1) of the Act where the principal mineral to be extracted is XXXXXXXXXX.

Position: Yes, provided that the project does not result in a quarrying operation.

Reasons: Favourable opinion from NRCan.