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8 October 2004 Internal T.I. 2004-0093371I7 F- Crédit d'impôt à l'investissement & impôt minimum-- summary under Subparagraph 127(5)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(5)- Paragraph 127(5)(a)- Subparagraph 127(5)(a)(ii) carryback of ITCs from year where the taxpayer was subject to minimum tax After noting that where minimum tax applies in a particular taxation year (here, 2003), the deductible amount of investment tax credit in respect of property acquired in that year is limited under s. 127(5)(b) to the amount by which the tax otherwise payable under Part I for the year (2003) exceeds the minimum tax applicable to the individual for that year, the Directorate went on to note that the unused investment tax credit balance be carried back to previous years (2000 to 2002) if the investment tax credit amount is higher than this excess: for purposes of the carryback to such prior years, s. 127(5)(a)(ii) takes into account the balance that was not deductible in the particular taxation year (2003). ...

26 March 2001 External T.I. 2001-0073495- MANUFACTURING & PROCESSING-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits After noting that the "processing of goods usually refers to a technique of preparation, handling or other activity designed to effect a physical or chemical change in an article or substance, other than natural growth", and that examples included galvanizing iron, dyeing fence posts, dehydrating foods and modernizing and pasteurising dairy products, the Agency indicated that "a recycling facility would generally qualify for the manufacturing and processing profits deduction.... ...

& Section 116116(5)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

14 March 2002 External T.I. 2002-0119695 F- Income & Losses/Business or Property-- summary under Agency Summary Under Tax Topics- General Concepts- Agency criteria applied for determining presence of agency Before confirming that ticket sales receipts of the taxpayer may have been generated as agent for charitable organizations, so that they did not generate income to the taxpayer, CCRA stated: In general, the CCRA agrees to recognize a principal-agent relationship between persons for tax purposes provided that: the relationship between the persons concerned is legally one of principal-agent; this implies, among other things, that the transactions relating to the agency are effective and complete from a legal standpoint; this relationship arises from a prior formal agreement and does not constitute an ex post facto arrangement; this relationship does not contravene any legislation; the relationship is not a sham; the relationship is disclosed to the CCRA and the relevant documents are provided to the CCRA at the appropriate time (generally when the relevant tax returns are filed); the facts of the particular situation support the existence of the principal-agent relationship between the persons concerned. ...

7 January 2004 Internal T.I. 2003-0038217 F- gain en capital / résidence principale-- summary under Paragraph 45(1)(c) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(c) no partial change of use of residence where rental operation was not a business, or the business was ancillary A taxpayer constructed a housing unit for his son and son's spouse on the second floor of his personal residence and incurred small losses in renting it out to him. ...

7 January 2004 Internal T.I. 2003-0038217 F- gain en capital / résidence principale-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit rental of second floor of house to son at cost was not a business A taxpayer constructed a housing unit for his son and son's spouse on the second floor of his personal residence and incurred small losses in renting it out to him. ...

1999 Ruling 9903543- TOTAL RETURN SWAPS & MUTUAL FUND TRUST-- summary under Subsection 18.1(15) Summary Under Tax Topics- Income Tax Act- Section 18.1- Subsection 18.1(15) An open-end unit trust invests the proceeds of a public offering in a note of a bank and then enters into a total-return swap with the Bank respecting a bond index (some of the components of which correspond to bonds held by the bank). ...

27 November 2018 CTF Roundtable Q. 13, 2018-0779991C6- 20(1)(c) & Triangular Amalgamation-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by parent for use in connection with a triangular amalgamation to redeem preferred shares issued by Target can be deductible In a triangular amalgamation, is the interest on a third party loan obtained by ParentCo to redeem preferred shares issued by TargetCo as part of the transaction deductible under s. 20(1)(c)? ...

15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6- 78(1)(b)(ii) deemed loan & thin capitalization-- summary under Subparagraph 78(1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 78- Subsection 78(1)- Paragraph 78(1)(b)- Subparagraph 78(1)(b)(ii) deemed s. 78(1)(b)(ii) loan is not also deemed to bear interest The thin cap rules apply to “outstanding debts to specified non-residents”, whose definition specifies that there is deductible interest paid or payable on them. ...

7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician-- summary under Income or Loss Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4)- Income or Loss royalty income was incident to composing active business Gagliese Productions found that a company which earned royalties from the daily activities of its sole shareholder and employee in writing and producing music for TV episodes was earning income from an active business rather than from a specified investment business. ...