13 May 2016 External T.I. 2016-0635601E5 F - Dépenses de commandite -- translation
Principal Issues: What is the tax treatment of some sponsorship expenses made to a golf club?
Position: None. General comments.
Reasons: Question...
27 June 2016 External T.I. 2016-0637341E5 F - Partnerships - Negative ACB -- translation
Principal Issues: 1. Whether subparagraph 53(2)(c)(v) would apply to the loans in the situation described in the letter 2. Whether the limited...
26 March 2015 Internal T.I. 2013-0503031I7 F - Existence d’une source de revenu -- translation
Principal Issues:
1) Do the taxpayer's activities qualify as a source of income?
2) If the taxpayer is carrying on a business, are the allowable...
7 December 2015 External T.I. 2015-0585171E5 F - 7(1)(b) benefit and 110(1.1) election -- translation
Principal Issues: Prior to the sale of the shares of a corporation to an arm’s length purchaser, in a situation where paragraph 7(1)(b) applies,...
28 January 2016 External T.I. 2015-0617771E5 F - Bump calculation -- translation
Principal Issues: Amounts to be included in 88(1)(d)(i)(B) - deferred income taxes
Position: Not to be included
Reasons: No legal obligation to...
Starlight No. 5 -- summary under LP Acquisitions of LPs
Overview
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...