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24 October 1995 External T.I. 9522905- HEALTH SPENDING ACCT WITH VARYING PLAN YRS & AMT OF CR Unedited CRA Tags 6(1)(a) 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. ... Principal Issues: 1) health spending account & whether the plan year can vary according to employee 2) can the plan use the health care spending account to adjust for changes in flex credits allocated by salary or for changes in cost of benefits-other issues include c/f of credits at year end, changes for life events Position: 1) yes, the plan year for each employee can begin with the employee's month of birth 2) no the amount of flex credits must be fixed at beginning of year & cannot be reallocated except in the event of a life event (although some portion of the fixed amount of credits allocated prior to the start of the plan yr may have been calculated with reference to the employee's salary at that time Reasons: if the credits can be transferred between options or if the amount of credits is not fixed, the credits may be seen as additional remuneration or the flex plan may be considered an employee benefit plan A. ...

3 May 2002 External T.I. 2002-0127425- surface lease & principal residence Unedited CRA Tags 54 9 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Position: 1. question of fact whether adjacent land can be considered part of principal residence- but- partial disposition may be recognized Reasons: 1. as per paragraphs 1 & 2 of IT-200- capital portion is treated as partial disposition; See also IT-120R5 paragraphs 15 &16 (land >1/2 hectare may qualify if zoning restrictions don't allow smaller lots) & paragraph 18 (re-partial disposition) Lena Holloway, CA XXXXXXXXXX 613-957-2104 2002-012742 May 3, 2002 Dear XXXXXXXXXX: Re: Surface Leases This is in reply to your letter dated March 7, 2002 regarding the receipt of payments pertaining to the first year of a surface lease granted on land. ...

4 April 2023 External T.I. 2023-0965171E5- MGHRTC – Newly constructed housing unit Unedited CRA Tags ITA: Section 122.92, Subsections 122.92(1), (3) and (4). ... An eligible individual in respect of an eligible dwelling includes: * an individual who ordinarily resides, or intends to ordinarily reside, in the eligible dwelling within 12 months after the end of the renovation period in respect of a qualifying renovation of the eligible dwelling and who is: (i) a qualifying individual, (ii) the cohabiting spouse or common-law partner of a qualifying individual at any time in the renovation period taxation year, or (iii) a qualifying relation of a qualifying individual; or * an individual who is a qualifying relation of a qualifying individual, and who owns the eligible dwelling A qualifying individual is defined as an individual who is 65 years of age or older at the end of the renovation period taxation year or an individual who is 18 years of age or older at the end of the renovation period taxation year who is eligible for the disability tax credit. ...

1 May 2023 External T.I. 2023-0965631E5- Mental functions & home accessibility tax credit Unedited CRA Tags 118.041 Principal Issues: 1. ... The terms qualifying individual, eligible individual, qualifying expenditure, qualifying renovation, and eligible dwelling are all defined in subsection 118.041(1) of the Act and explained on the Canada Revenue Agency (CRA) webpage, titled “Line 31285 – Home accessibility expenses” at canada.ca/line-31285. ... In the situation you described, while the removal of asbestos tiles on the ceiling and floor does not on its own qualify for the HATC, it may qualify, however, if done as part of a qualifying renovation – which seems to apply to the creation of a safe play and therapy area for your children. ...

24 August 1998 External T.I. 9805845- FARMERS & TIMBER Unedited CRA Tags 110.6(1) 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. ... Do they answers to 1 & 2 change if the property was transferred to the taxpayers son in 1985? ... All of the comments in 1 & 2 would apply to the son. 4. It depends. 5. ...

3 June 1997 External T.I. 9711835- CONTRACTUAL ARRANGEMENT & SPOUSAL TRUST Unedited CRA Tags 70(6) 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. ...

8 August 1997 External T.I. 9720285- SALE & REPURCHASE OF ASSETS BY RRSP Unedited CRA Tags 206(2) 245(2) 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. ...

8 February 1999 External T.I. 9827525- INSURED ANNUITIES & PART XI TAX Unedited CRA Tags 206(2) 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. ...

5 August 1994 External T.I. 9417745- NON-PROFIT CORPORATION FOR SR & ED Unedited CRA Tags 149(1)(j) 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. ...

18 October 1993 External T.I. 9325095 F- HAA7255-4 Qualifying Home Demolished & Rebuilt Unedited CRA Tags 146.01 XXXXXXXXXX Dear Madam: RE:  Qualifying Home under the Home Buyers Plan This is in reply to your letter of August 30, 1993, in which you request a ruling that a new modular home to be built on a new foundation will be a qualifying home under the home buyers plan where the new residence will be built on the same lot as your existing residence after it is demolished. ...