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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) …. ...

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. ...

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. ...

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) 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. ...

., 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. ...

10 December 2014 Internal T.I. 2014-0533151I7- Qualified Donee- XXXXXXXXXX-- summary under Paragraph 149(1)(c) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(c) Park needs to demonstrate it is performing municipal-type services A Park was established to encourage an appreciation and use of natural and recreational resources, was authorized under its constituting [Statute?] ... A review of the Park's financial statements fails to show any significant expenditure on infrastructure such as roadways, buildings, and sewer systems it claims to be providing. … In addition, while the Park… has not provided any evidence to support that they have in fact passed bylaws. … Other evidence to support that the Park is performing a function of government may include: a copy of an agreement with a neighboring municipality to provide fire protection or waste removal services, invoices from organizations subcontracted to provide the municipal type services on behalf of the Park, and the name of the municipality that is charged with collecting taxes on behalf of the Park and the agreement that governs the relationship. ...

. … [W]hen a foreign trust grants funds to other organizations…the recipient organization would have to be considered “charitable” according to Canadian common law.... [W]hen the charitable activities are carried out by an intermediary…the activities and the underlying resources provided must be subject to the direction and control of the trust…. ...

Aco, a wholly-owned Canadian mining and exploration subsidiary, has four “unproven resource properties” (the “Properties”) at a stage such that exploration expenses incurred thereon would still qualify as Canadian exploration expense (“CEE”). ... Rulings Re qualification of expenditures under CEE – (f) and non-application of s. 245(4), and that s. 66(12.71) will not apply to prevent Bco from renouncing CEE provided that it is carrying on business in Canada. ...

Aco, a wholly-owned Canadian mining and exploration subsidiary, has four “unproven resource properties” (the “Properties”) at a stage such that exploration expenses incurred thereon would still qualify as Canadian exploration expense (“CEE”). ... Rulings Including re qualification of expenditures under CEE – (f). ...