Starlight No. 5 -- summary under Foreign Asset Income Funds and LPs
16 June 2016 Internal T.I. 2015-0597971I7 F - Perte réputée nulle - loss deemed nil -- translation
Principal Issues: The question is whether a debt was acquired by the taxpayer for the purpose of gaining or producing income from a business or...
17 May 2016 External T.I. 2015-0603711E5 F - Personne assumant les frais d'entretien -- translation
Principal Issues: Is the parent who is not residing in Canada with his/her spouse considered a supporting person for the purpose of claiming child...
Lightstream Resources -- summary under Recapitalizations or note exchanges
Overview
Lightstream Resources carries on its business through two partnerships. As at the end of 2015, it had $1.53B in Canadian tax pools...
11 August 2015 External T.I. 2014-0527291E5 F - Remboursement de frais médicaux-CIMAD -- translation
Principal Issues: 1- Whether the position stated in document 2001-0113237 is still valid following the change in position stated in document
15 December 2015 External T.I. 2015-0602671E5 F - Pompier volontaire -- translation
Principal Issues: What is the CRA's position regarding the notion of "volunteer firefighter" for the purposes of subsection 81(4) and section...
11 April 2016 External T.I. 2015-0564161E5 F - IT-522R par. 36 -- translation
Principal Issues: Is the CRA position in paragraph 36 of IT bulletin IT-522R still valid?
Position: Yes
Reasons: The CRA's position in paragraph...
27 April 2016 External T.I. 2016-0625001E5 F - Surplus Stripping -- translation
Principal Issues: In a particular situation, a trust (hereinafter "Trust") was established under the Civil Code of Quebec. Trust is a...
2 May 2016 External T.I. 2016-0633351E5 F - Descarries Case and Document no. 2015-0610711C6 -- translation
Principal Issues: Whether we would take a different position from the one taken in document no. 2015-0610711C6 with respect to the application of...