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31 December 2015 External T.I. 2014-0556881E5- Bill C-43 – Calendar year for testamentary trusts CRA Tags 248(1) Principal Issues: Change in tax treatment of testamentary trusts arising from Bill C-43 may result in a deemed tax year end of December 31, 2015. ... King December 31, 2015 Dear XXXXXXXXXX: Re: Bill C-43 – Calendar year for testamentary trusts This is in reply to your email correspondence and our telephone conversations during which you asked if there is any transitional relief with respect to the legislative changes in Bill C-43 which require an existing testamentary trust, which will not be a graduated rate estate, to have a taxation year that coincides with the calendar year; commencing with a deemed taxation year of December 31, 2015. ...

26 July 2012 External T.I. 2011-0431681E5- Taxable Benefits – Recreational Facilities Unedited CRA Tags 6(1)(a) Principal Issues: 1. ... Baltkois July 26, 2012 Dear XXXXXXXXXX: Re: Taxable Benefits – Recreational Facilities We are writing in response to your fax dated December 8, 2011, in which you requested our comments as to whether an employee’s use of an employer provided in-house fitness centre would result in a taxable benefit. ...

18 March 2014 External T.I. 2013-0511191E5- Taxable Benefits – Weight Management Programs CRA Tags 6(1)(a) 6(1)(a)(iv) Principal Issues: Whether an employer-subsidized weight management program is a taxable employment benefit? ... Baltkois March 18, 2014 Dear XXXXXXXXXX: Re: Taxable benefits – weight management program We are writing in response to your correspondence dated November 1, 2013, wherein you requested our comments concerning whether a weight management program subsidized by an employer as part of an overall wellness initiative would result in a taxable benefit to participating employees. ...

26 May 2016 External T.I. 2016-0627441E5- Employment expenses – long-haul truck driver Unedited CRA Tags 8(2), 8(1)(g), 8(1)(h), 8(1)(h.1), 8(1)(i)(iii), 8(1)(j), 8(4), 8(10), 67.1(1), 67.1(5), 67.1(1.1), 230(1), 248(1) Principal Issues: Deductibility of expenses by a long-haul truck driver. ... Underhill May 26, 2016 Dear XXXXXXXXXX: Re: Employment expenses – long-haul truck driver We are writing in response to your letter dated December 29, 2015, concerning what expenses a long-haul truck driver may deduct from his or her employment income. ...

5 November 1998 External T.I. 9818445- JOINT TENANTS & TENANTS IN COMMON Unedited CRA Tags 70(5) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reasons: The provision of subsection 70(5) will deemed the interest in the property to be disposed of at fair market value under both tenancy arrangements. 5-981844 XXXXXXXXXX Karen Power, CA (613) 957-8953 November 5, 1998 Dear XXXXXXXXXX: Re: Joint Tenancy & Tenants in Common We are writing in reply to your letter of June 8, 1998, concerning the taxation of property owned by yourself and your brother and sister. ...

1 August 2019 External T.I. 2018-0768561E5- Application Administrative Position on US LLPs & LLLP Unedited CRA Tags 248(1) "corporation" Principal Issues: Further to the CRA's administrative position that a LLP or LLLP formed before April 26, 2017 that would otherwise be viewed as a corporation by the CRA may in certain circumstances continue to be viewed as a partnership, what are the Canadian tax implications of the LLLP described in this letter subsequently taking the position that it is a corporation for Canadian tax purposes? ... Moreno August 1, 2019 Dear XXXXXXXXXX: Re: Administrative Position on US LLPs & LLLPs This is in reply to your letter of June 29, 2018. ...

21 February 2024 External T.I. 2022-0951441E5- Replacement Property – Undivided Interest Unedited CRA Tags 13(4), 13(4.1), 44(1), 44(5), 54 "capital property", 248(1) “Property" Principal Issues: Where a taxpayer acquires an undivided interest in a particular property, whether the particular property can qualify as a "replacement property”, as defined by subsections 13(4.1) and 44(5) of the Act? ... XXXXXXXXXX 2022-095144 Troy Neave February 21, 2024 Dear XXXXXXXXXX: Re: Replacement Property – Undivided Interest We are writing in response to your letter dated September 3, 2022, wherein you requested our views on whether, for purposes of the replacement property rules in subsections 13(4) and 44(1) of the Income Tax Act (the “Act”), a particular property could be considered a replacement property if the nature of ownership is an undivided interest. ...

25 March 2025 External T.I. 2025-1049301E5- METC- Hyperbaric oxygen chamber & concentrator Unedited CRA Tags Subsection 118.2(2) ITA; Paragraphs 118.2(2)(i) and (k) ITA; Paragraph 118.4(2)(c) ITA Principal Issues: Whether the amounts paid to acquire 1) a portable oxygen concentrator and 2) a hyperbaric oxygen chamber would qualify as eligible medical expenses for the purposes of the medical expense tax credit (METC). ... XXXXXXXXXX 2025-104930 Éloïse Lafortune Viger March 25, 2025 Dear XXXXXXXXXX, Re: Medical Expense Tax Credit – Portable Oxygen Concentrator and Hyperbaric Oxygen Chamber We are writing in response to your letter dated October 16, 2024, inquiring whether the amounts paid to acquire a portable oxygen concentrator and a hard shell hyperbaric oxygen chamber would qualify as eligible medical expenses under subsection 118.2(2) of the Income Tax Act (the “Act”) for the purposes of the medical expense tax credit (“METC”). ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1) Unedited CRA Tags 250(1)(a) ART IV and XV REG 105 110(1)(f)(i) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... We are not able to find any references in the case of R & L Food Distributors Ltd. 1 ("R & L") described in your letter that a "day" refers to each 24 hour period. ... Yours truly, for Director Reorganizations and Foreign Division Rulings Directorate Policy and Legislation Branch 1 R & L Food Distributors Ltd. v. ...

27 August 2012 External T.I. 2012-0438001E5- Taxable Benefits – Employer-Provided Vehicles Unedited CRA Tags 6(1)(a); 6(1)(e); 6(1)(k); 6(6) Principal Issues: 1. ... Baltkois August 27, 2012 Dear XXXXXXXXXX: Re: Taxable Benefits – Employer-Provided Vehicles We are writing in response to your email dated February 22, 2012, in which you asked whether an employee’s use of an employer-provided motor vehicle would give rise to a taxable benefit under the Income Tax Act (the “Act”) for various scenarios. ... Additional information on this subject is available in Interpretation Bulletin IT-63R5, Benefits, Including Standby Charge for an Automobile, from the Personal Use of a Motor Vehicle Supplied by an Employer- After 1992, Form RC18 – Calculating Automobile Benefits for 2011, and through the Automobile Benefits Online Calculator which is available on the CRA website. ...