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25 January 2018 External T.I. 2017-0709241E5- Subsections 125(3.2) & 125(5.1)-- summary under Subsection 125(5.1) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(5.1) business limit is ground first based on taxable capital before it can be assigned Does the assignment of the business limit under s. 125(3.2) occur before or after the business limit reduction in s. 125(5.1)? After noting that under s. 125(5.1) “the business limit … is reduced on a straight-line basis if the total of the taxable capital of the CCPC (employed in Canada) and, if applicable, of [associated] corporations … exceeds $10 million … [so that] once the taxable capital … reaches $15 million its business limit would be zero,” CRA stated:. ...

30 October 2003 External T.I. 2003-0037465 F- Subsections 40(3.3) & 40(3.4)-- summary under Subsection 40(3.4) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.4) non-application of s. 40(3.4) where taxpayer acquires then immediately disposes of an additional block/ application of formula where it partially dips into existing block A taxpayer described in s. 40(3.3)(a), which on January 1, 200X had held 100 common shares of Pubco for at least three months, acquired an additional 50 shares on June 1, 200X, and on June 2, 200X, disposed of those additional shares to an unaffiliated person, sustaining a capital loss.. ... CCRA indicated that although s. 40(3.4) would apply, under its administrative position, only 1/2 of the taxpayer's loss would be considered to be nil under s. 40(3.4)(a) under the formula: Deemed nil loss = (the lesser of S, P and B) / S x L where S = the number of shares disposed of at that time 100 P = the number of shares acquired during the period described in paragraph 40(3.3)(b) 50 B = the number of shares remaining at the end of that period 50 L = the loss on the disposition otherwise determined And therefore: Deemed nil loss = 50 / 100 x L CCRA indicated that s. 40(3.4) would apply to the entire loss arising under a second variation, under which, on June 1, 200X, the taxpayer disposed of 50 of the 100 Pubco common shares and on June 2, 200X, acquired an additional 50 Pubco common shares of Pubco. ...

17 February 2017 External T.I. 2016-0662341E5- Airline passes – retired and current employees-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) use of space-confirmed, but not standby, passes by airline employees is taxable Will S2-F3-C2 be revised to reflect the administrative policies in IT-470R, paras. 42, 44 respecting standby airline passes provided to current airline employees (“current employees”) and standby and space-confirmed airline passes provided to retired airline employees (“retired employees”)? ... …[S]tandby and space-confirmed airline passes used by retired employees are not taxed. … S2-F3-C2 … provide[s] CRA’s interpretive positions, not administrative policies. … The CRA webpage, Benefits and allowances, will be updated to include these administrative policies. ...

6 October 2017 APFF Roundtable Q. 1, 2017-0708971C6 F- Inactive Corporations & subs. 162(7) ITA-- summary under Subsection 162(7) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(7) no penalty imposed where failure to file a nil T2 return At the 2016 APFF Conference, CRA indicated that an inactive corporation must file an income tax return, but could file a letter explaining the non-filing, and that a penalty would not be automatically imposed. ... After noting that such filing was required by s. 150(1)(a)(i)(A), CRA stated: … Exida.com … stated that the general penalty in subsection 162(7) was applicable … where a person fails to comply with an obligation imposed on the person … unless another provision of the Income Tax Act provides for a penalty for such default. … However … the CRA [considers] that since this decision is based on a rather narrow interpretation of the relevant statutory provisions, the penalty under subsection 162(7) will generally not be imposed on resident corporations that failed to file their tax returns where they either had no taxable income or had incurred a loss for the year. ...

29 September 2020 External T.I. 2018-0757501E5 F- Crédit pour intérêts sur les prêts étudiants-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt capitalization of interest on a novation under Quebec law would constitute its payment A Quebec post-secondary student loan program provided for an initial 12-month “full exemption period” (in which the Quebec government paid the interest charged on the loan by the lender) and a subsequent six-month “partial exemption period” (during which the student borrower was required to pay interest on the loan balance). ... In addressing whether such capitalized interest qualified as being “paid” under a “loan made” under the Quebec financial assistance program so as to generate a credit under s. 118.62, CRA stated: By virtue of the Civil Code of Quebec, there can be payment where there is a handing over of money [(“tradition d’argent”)] between the debtor and the creditor or where there is novation by change of debt. … The mere addition of accrued interest to the principal amount of an original debt is generally not sufficient in itself to constitute a payment of such interest. If … the addition of interest to the principal … qualifies as a novation … the amount of interest will be considered paid when the novation occurs and will be eligible for the credit by virtue of section 118.62, if all the conditions set out in that section are otherwise satisfied. ...