2024-01-24 |
21 December 2023 External T.I. 2016-0654081E5 F - Transfer of life insurance |
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21 December 2023 External T.I. 2019-0822121E5 F - Transfer of life insurance policy from a trust to |
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21 December 2023 External T.I. 2020-0866651E5 F - Transfer of life insurance |
Income Tax Act - Section 148 - Subsection 148(7) |
a trust distribution of a life insurance policy to a beneficiary treated as being made for FMV consideration equal to the part of the beneficiary’s capital or income interest that is satisfied
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3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 2, 2023-0978631C6 F - CELIAPP - Autoconstruction d'une habitation - FHSA - Self-construction |
Income Tax Act - Section 146.6 - Subsection 146.6(1) - Qualifying Withdrawal - Paragraph (a) |
acquisition of home is when it becomes habitable |
Income Tax Act - Section 146.6 - Subsection 146.6(1) - Qualifying Withdrawal - Paragraph (c) |
written agreement for construction before October 1 could be satisfied with agreements with trades by self-constructing individual |
2002-05-10 |
9 May 2002 Internal T.I. 2002-0135307 F - Application du paragraphe 39(2) |
Income Tax Act - Section 90 - Subsection 90(3) |
distribution of contributed surplus by Delaware subsidiary likely was a dividend |
Income Tax Act - Section 39 - Subsection 39(2) |
distribution by Delaware subsidiary that did not result in s. 40 application thereby did not engage s. 39(2) |
Income Tax Act - Section 248 - Subsection 248(1) - Dividend |
a dividend is any corporate distribution other than of PUC |
2002-04-26 |
15 May 2002 External T.I. 2001-0107805 F - PLUSIEURS ENTREPRISES |
Income Tax Act - Section 98 - Subsection 98(5) |
where the terminated partnership carried on more than one business, s. 98(5) requires the sole proprietor to carry on all of those businesses |
Statutory Interpretation - Interpretation Act - Subsection 33(2) |
reference to “the” business included all the businesses |
14 May 2002 External T.I. 2001-0105925 F - TOTALITE DES ACTIFS DE L'ENTREPRISE |
General Concepts - Illegality |
in 1996, the transfer of inventories of a Quebec pharmaceutical business to a wholly-owned corporation would have been invalid |
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(f) - Subparagraph 110.6(14)(f)(ii) - Clause 110.6(14)(f)(ii)(A) |
unclear whether pharmaceuticals inventory could be transferred to a corporation owned by a pharmacist |
17 May 2002 External T.I. 2001-0107815 F - APPLICATION DE LA LOI |
Income Tax Act - Section 34.1 - Subsection 34.1(8) |
s. 34.1(8) would apply if an old partnership is replaced by a new one, provided no tax avoidance motivation |
Income Tax Act - Section 96 |
s. 249.1(1) overrode the normal perspective that the partnership business was carried on by the partners both before and after a new partnership was formed |
21 May 2002 External T.I. 2002-0133105 F - COUT DES ACTIONS |
Income Tax Act - Section 112 - Subsection 112(5.2) - Variable B |
s. 47(1) does not apply to determine the loss on mark-to-market property shares for the purposes of B in s. 112(5.2) |
21 May 2002 External T.I. 2001-0097215 F - DISPOSITION D'UN BIEN EN IMMOBILISATION |
Income Tax Act - Section 248 - Subsection 248(1) - Disposition |
disposition of land when sold by municipality for unpaid property taxes |