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These are additions to our set of 3,195 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,209 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,221 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ½ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2025-07-02 29 April 2025 External T.I. 2024-1036641E5 F- Relevant Group Entity Income Tax Act- Section 84.1- Subsection 84.1(2.31)- Paragraph 84.1(2.31)(c)- Subparagraph 84.1(2.31)(c)(iii) a Realtyco, whose shares qualified as QSBCS based on a related corporation’s active business, would be a “relevant group entity” on a sale of the latter’s shares Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(c)- Subparagraph 84.1(2.32)(c)(iii) continued control of the related lessor to an Opco would violate the s. 84.1(2.32)(c)(iii) condition on a sale of Opco to a child’s purchaser corporation 2000-06-23 10 May 2000 Internal T.I. 2000-0016257 F- RPA COTISATIONS POUR SERVICES ANTERIEURS Income Tax Act- Section 147.2- Subsection 147.2(4)- Paragraph 147.2(4)(c) no retroactive deduction 19 May 2000 Internal T.I. 2000-0018477 F- DEDUCTION A LA SOURCE Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(j) amounts paid out of RRSP to trustee in bankruptcy pursuant to judgment were subject to source deductions even though no mention thereof in court order 2000-06-09 8 June 2000 External T.I. 1999-0006105 F- TRANSFERT DE BIENS A UN CONJOINT Income Tax Act- Section 74.1- Subsection 74.1(1) CCRA has not yet developed a position re where the transferred property itself is returned to the transferor spouse in repayment of the transferee spouse’s debt 15 May 2000 Income Tax Severed Letter 2000-0008210 F- ADMINISTRATEUR DE FACTO Income Tax Act- Section 227.1- Subsection 227.1(1) individual can be a de facto director who acts as such with the shareholders’ agreement or takes significant actions with 3rd parties in the corporation’s name 31 May 2000 External T.I. 2000-0009695 F- FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) meaning of “one full-time attendant … for the full-time care of the individual” 5 June 2000 External T.I. 2000-0010615 F- Developpement d'un equipement- RS&DE Income Tax Act- Section 37- Subsection 37(8)- Paragraph 37(8)(d) expenditures to develop SR&ED equipment could be current expenses ...

These are additions to our set of 3,310 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 25 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,330 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 25 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,348 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 25 ½ years of releases of such items by the Directorate. ...

Bundle Translated severed letter Summaries under Summary descriptor 2016-11-16 24 June 2016 External T.I. 2015-0571471E5 F- Passe de ski familiale Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) no taxable benefit if all employees given season’s pass at ski resort/gift policy also applicable 2 August 2016 External T.I. 2014-0544941E5 F- Interaction between ss. 111(12) and 80.01(3) Income Tax Act- Section 80.01- Subsection 80.01(3) deemed settlement under 80.01(3) before operation of 111(12) Income Tax Act- Section 111- Subsection 111(12) no accrued FX loss on a loan owing by a target to a sub is realized on an AOC where there is a same-day amalgamation and no time-stamping 2016-10-19 22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) inter-affiliate loan generating deemed active business funded out of an interest-free loan from Canco Income Tax Act- Section 248- Subsection 248(5) ordinary meaning of “substituted” Income Tax Act- Section 93- Subsection 93(2.01) a contribution of FA1 shares to FA2 causes the FA2 shares to be substituted property for s. 93(2.01) purposes 2016-01-20 3 December 2015 External T.I. 2015-0593941E5 F- Allocation of the safe income on hand General Concepts- Fair Market Value- Shares FMV of discretionary share increased at moment of dividend declaration to exclusion of other discretionary shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) flexible allocation of SIOH where discretionary common shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) quaere whether 8% reduction is significant 26 March 2015 Internal T.I. 2013-0503031I7 F- Existence d’une source de revenu Income Tax Act- Section 3- Business Source/Reasonable Expectation of Profit individual’s sideline activity not a business so that revenues exempt Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose criteria for determining whether a home is a principal place of business 8 December 2015 External T.I. 2015-0616321E5 F- CEE- Severance pay Income Tax Regulations- Regulation 1206- Subsection 1206(1)- Canadian exploration and development overhead expense exclusion of severance payment Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (a) severance payment not includible in CEE 8 June 2015 External T.I. 2014-0529851E5 F- Frais payés à une maison de santé ou de repos Income Tax Act- Section 118.2- Subsection 118.2(1) expenses can be claimed based on 12-month period ending in year Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(d) floor of retirement residence servicing those with advanced Alzheimer’s can qualify as “nursing home” Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(e) no 2nd credit under s. 118.3 re accommodation expenses in nursing home 11 December 2015 External T.I. 2015-0601561E5 F- Attribution Rules Income Tax Act- Section 74.4- Subsection 74.4(2) annual dividends by an SBC to a non-SBC are not an indirect transfer of property to the non-SBC by the individual who formed the SBC ...

T.I. 2012-0463801E5 F- Déduction pour gain en capital – permis de pêche Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(b) para. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2017-03-15 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.1, 2016-0674221C6 F- General deduction from tax- 123.4 Income Tax Act- Section 123.4- Subsection 123.4(1)- Full Rate Taxable Income income on which the SBD was not claimed nonetheless is not eligible for the general rate deduction 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.2, 2017-0682711C6 F- Dedicated Telephone Service for Income Tax Service Income Tax Act- Section 152- Subsection 152(1) telephone service for those with complex technical tax issues will initially be limited to Ontario and Quebec CPAs 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.3, 2016-0674821C6 F- Individuals separated living under the same roof Income Tax Act- Section 122.6- Cohabiting Spouse or Common-Law Partner couple under the same roof can be living separate and apart Income Tax Act- Section 248- Subsection 248(1)- Common-Law Partner meaning of living "separate and apart" 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.4, 2016-0674831C6 F- Changement d'usage- duplex Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(c) substantially renovating the personal-use portion of a rental property (without changing floor areas) generally would not engage the change-of-use rules Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) apportionment of operating expenses of duplex used both personally and for rental income Income Tax Act- Section 248- Subsection 248(1)- Property duplex is single property 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.5, 2016-0674801C6 F- Allocation et frais d'une automobile Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(k)- Subparagraph 6(1)(k)(v) electric vehicles treated the same Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) general reasonability of a car allowance rate of $0.54/$0.48 per kilometre including for electric vehicles 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.6, 2016-0674861C6 F- Wholly dependent person tax credit Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b)- Subparagraph 118(1)(b)(ii) meaning of support/legal custody not required/ITA is silent on number of days child must spend with parent 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.7, 2016-0674811C6 F- Allocations automobiles & dépenses afférentes Income Tax Regulations- Regulation 200- Subsection 200(3) correction of T4s Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) if vehicle allowance is too low, employee can include the allowance and deduct the vehicle expenses/T2200 production expected 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.8, 2016-0674851C6 F- HBTC- Acquisition by way of gift Income Tax Act- Section 118.05- Subsection 118.05(1)- Qualifying Home gifted home can qualify for the HBTC ...