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9 December 2020 External T.I. 2020-0852321E5 - Flow Through Shares - Fees Paid to Promoter -- summary under Paragraph 6202.1(1)(b)

9 December 2020 External T.I. 2020-0852321E5- Flow Through Shares- Fees Paid to Promoter-- summary under Paragraph 6202.1(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 6202.1- Subsection 6202.1(1)- Paragraph 6202.1(1)(b) payment by a flow-through share issuer of fees for investor procurement services of an arm’s length promoter would not taint the shares as prescribed shares A principal-business corporation (the “Issuer”) issues publicly-listed shares pursuant to flow-through share agreements to individual investors (the “Investors”), who sell their shares to an end-purchaser (the “Liquidity Provider”) after the renunciation of eligible resource expenditures. ... Generally, we would not expect that the payment of an Offering Assistance Fee by the Issuer to the Promotor of a FTS offering would, in and by itself, cause shares issued under the FTS offering … [under] section 6202.1 … if the Offering Assistance Fee is paid in circumstances where all the parties involved in the FTS offering, namely the Issuer, the Investor, the Promotor and the Liquidity Provider, deal with one another at arm’s length and the amount of the Offering Assistance Fee is equal to the fair market value of the services for which it is paid. … [A]ll of the facts and circumstances surrounding a FTS offering would need to be considered in detail before concluding whether a particular share issued under that FTS offering is a prescribed share …. ...

Alta Energy Luxembourg S.A.R.L. v The Queen, 2018 TCC 152, aff'd 2020 FCA 43, aff'd 2021 SCC 49 -- summary under Article 13

Alta Energy Luxembourg S.A.R.L. v The Queen, 2018 TCC 152, aff'd 2020 FCA 43, aff'd 2021 SCC 49-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 a large exploration property in which only six wells had been drilled qualified as immovable property used in the business A U.S. corporation (“Alta Resources USA”), which was a leader in the development of shale oil and gas assets in the U.S., and a Blackstone-affiliated partnership with approximately equal ownership by U.S. ... This provision would have deemed the shares of Alta Canada to be immovable property (thereby permitting the gain from their disposition to be subject to Canadian capital gains tax) on the basis that they derived their value principally from immovable property situated in Canada, subject to an exclusion which deemed the underlying licences not to be immovable property if they were property of Alta Canada “in which the business of the company … was carried on.” ...

Investissement Boeckh Inc. v. Agence du revenu du Québec, 2023 QCCA 633 -- summary under Paragraph 39(5)(a)

Boeckh was a closely-held investment company whose portfolio (of over $100 million for many of the years) was focused on junior Canadian public companies in the resource and high tech sectors. ... An interpretation of TA section 250.3 that differed from that of its federal equivalent in ITA subsection 39(5) would derogate from this legislative objective. … [I]n tax matters, where the federal and provincial provisions are appreciably in the same form, a presumption of coherence between the two provisions should prevail. ...

Bell v. The Queen, 2016 TCC 175 -- summary under Section 87

The taxpayer, who was the sole director and President, performed human resources, back office and administrative functions at an office on the reserve, whereas her husband planned, scheduled and placed rebar, and worked with their 50 employees on the construction sites. ... Further, I find that it is abusive of the exemption for the Appellant to receive bonuses which exceed reasonable remuneration. … [T]here was no evidence…that the bonuses were…intended…to reasonably compensate the Appellant for her duties of employment. … [T]he Appellant received remuneration through her bi-weekly pay that was roughly equivalent to Mike’s remuneration, except for 2008 when the Appellant’s regular pay exceeded Mike’s. ...

15 February 2023 Internal T.I. 2022-0925731I7 - Qualified donee - Article XXI of Canada-US Treaty -- summary under Article 21

XXI(7) of the Canada-US Treaty treats gifts to U.S. 501(c)(3) organizations as eligible gifts, but does not permit registered charities to make such gifts A public foundation disbursed funds, by way of unrestricted gifts, without direction and control over the resources gifted, to certain U.S. 501(c)(3) organizations during taxation years ending prior to 2022. ... The CRA accepts that, pursuant to the tax relief measure described in paragraph 7 of Article XXI … a gift made by a Canadian resident to a U.S. 501(c)(3) organization will be an eligible gift for purposes of the deduction in computing taxable income under section 110.1 …. or a non-refundable tax credit … under section 118.1 … subject to the income limitations, described in those sections, from U.S. sources. ... Accordingly … Article XXI[(7)] of the Canada-U.S. Treaty does not deem a U.S. 501(c)(3) organization to be a qualified donee, for purposes of subsections 149.1(2), (3) and (4) …. ...

2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F - APFF - Congrès 2023 - Table ronde sur la fiscalité -- summary under Subsection 69(4)

Regarding Girard, CRA stated: The CRA does not consider that it must apply to the court in all cases where it issues a notice of assessment following a bankruptcy or the filing of a proposal for a tax debt relating to a taxation year ending on a day preceding the date of the bankruptcy or proposal, in order to ensure sound administration and reasonable use of judicial resources. ... Where the particular context of a case so requires, in applying Girard, the CRA will seek leave of the court under section 69.4 B.I.A. to lift the stay of proceedings. … In Girard, the presumption of validity of notices of assessment under subsection 152(8) I.T.A. was not at issue. … In the event that a trustee contests the CRA's proof of claim, the legal effects of the notice of assessment, including the procedure for contesting the assessment and the time limits associated with it, are suspended until the CRA obtains the lifting of the suspension of proceedings under section 69.4 B.I.A., pursuant to the Girard decision. ...

7 March 2012 External T.I. 2011-0421301E5 F - Bien agricole admissible -- summary under Paragraph (a)

CRA stated: If the main focus of a business conducted with a reasonable expectation of profit (a commercial woodlot) is not lumbering or logging, but is planting, nurturing and harvesting trees pursuant to a forestry management or other similar resource plan and significant attention is paid to manage the growth, health, quality and composition of the stands, it is generally considered a farming business (a commercial farm woodlot). If the main focus of a business is logging (a commercial non-farm woodlot), and is not growing, nurturing and harvesting trees, the fact that reforestation activities are carried out would not transform that business into a farming operation. … [T]he forestry activities that take place on your farmland are farming. ...

4 October 2010 External T.I. 2010-0376111E5 F - Frais de scolarité - formation continue -- summary under Clause 118.5(1)(a)(ii.2)(B)

After indicating that the courses offered by your institution “would not be post-secondary level courses since they do not lead to university credits” so that they did not qualify under s. 118.5(1)(a)(i), CRA went on to discuss ss. 118.5(1)(a)(ii) and (ii.2)(B), and stated: In addition to being recognized by the Minister of Human Resources Development as a recognized educational institution, the conditions in subparagraph 118.5(1)(a)(ii.2) must be satisfied for continuing education courses you offer to individuals who are members of a professional order to be eligible for the tuition tax credit. ... Whether it is reasonable to consider that the reason for an individual's registration at an institution is to enable the individual to acquire or improve the skill necessary to carry on an occupation is a question of fact …. ...

11 January 2005 Internal T.I. 2004-0104341I7 - Reclassify CDE of partnership to CEE -- summary under Subsection 66.1(9)

11 January 2005 Internal T.I. 2004-0104341I7- Reclassify CDE of partnership to CEE-- summary under Subsection 66.1(9) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(9) "... paragraph (f) of the definition of CDE (which allocates the partner's share of CDE incurred by the partnership) does not contain any wording which changes the character of the expenses from the original character, i.e., the original character being expenses referred to in paragraphs (a) to (e) of the definition of CDE. ... It is our opinion, based on the overall scheme of the relevant resource provisions that the word 'taxpayer' in subsection 66.1(9) of the Act and in paragraph (e) of the definition of CEE should be interpreted as referring only to a partner of a partnership and not to the partnership. ...

10 May 2001 Internal T.I. 2001-0066047 F - CRITERES RÉSIDENCES D'ACCUEIL -- summary under Paragraph 81(1)(h)

., the owner of the foster home, the foster family or the intermediate resource) or that place, i.e., the taxpayer's principal place of residence, is maintained for use by the beneficiary as a place of residence. ... Regarding the meaning of "or the taxpayer’s principal place of residence is maintained for use as the residence of that other individual,” the Directorate stated: The phrase … refers to specific situations, such as where a taxpayer receives amounts because the taxpayer’s principal place of residence is available to host beneficiaries at any time for various periods. ...

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