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8 June 2018 Internal T.I. 2018-0744881I7- Regulation 403 – allocation of income Unedited CRA Tags 138, 248 (definition of insurance corporation), Regulations 400 and 403 Principal Issues: For the purposes of taxable income allocation under Regulation 403, should the taxpayer ignore the PEs of the partnerships in which the taxpayer is a partner? ... & Investigations Branch Lata Agarwal, CPA, CMA, MBA 2018-074488 Provincial income allocation – permanent establishments of insurance corporation We are writing in response to your email dated February 20, 2018, in which you have asked us to confirm the CRA’s position stated in technical interpretation (“TI”) E56239 that each member of a partnership has a permanent establishment (“PE”) in the province in which the partnership has a PE. Your email describes a corporate taxpayer that filed Form T2 Schedule 5, Tax Calculation Supplementary – Corporations, for its XXXXXXXXXX taxation year, as an insurance corporation under section 403 of Part IV of the Income Tax Regulations (the “Regulations”). ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit Unedited CRA Tags 126 4 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. ... Other jurisprudence that supports the principle that a business is generally considered to be carried on in the place where the operations from which the profits arise are located and not necessarily where the sales contracts are made include: (a) F.L.Smidth & Co. v. ... (b) Firestone Tyre & Rubber Co., Ltd. V. Lewellin (HM Inspector of Taxes) (1957, 37 TC 111, at 142, "It follows then that the place of sale will not be the determining factor if there are other circumstances present that outweigh its importance or unless there are no other circumstances that can. ...

20 June 2007 Internal T.I. 2006-0178941I7- Foreign Spin-off & Foreign Merger Unedited CRA Tags 86.1(1) 87(8) 87(8.1) Principal Issues: 1. ... Newco shares were not listed under a symbol proper. • No information concerning the buying or selling transactions of Newco shares were provided. ... Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

30 September 2013 Internal T.I. 2012-0439661I7- Income earmarked for future use & 95(2)(a)(i) CRA Tags 95(1) 95(2)(a)(i) Principal Issues: Whether the income earned by one foreign affiliate on property that is earmarked for future development of another foreign affiliate's active business can be included in income from active business under paragraph 95(2)(a). ... In other words, the property has to be an integral part of the financing of the business or necessary to the overall business operations in order for income from the property to be part of the income of the corporation … from an active business. ... MNR, 87 DTC 450 at 457; McCutcheon Farms, supra note 2 at 1214; Transport Lacte Inc, supra note 3 at 610; Muir Cap & Regalia Ltd v. ...

6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property CRA Tags 110.6(1) 95(1) 149(10) Principal Issues: Whether internally generated goodwill should be considered in the determination of the excluded property status of shares of a foreign affiliate held by another foreign affiliate? ... Truong: Internally Generated Goodwill & Excluded Property Status We are writing in response to your e-mail dated June 25, 2014 wherein you asked whether internally generated goodwill should be considered in determining whether shares of a foreign affiliate ("FA2") of a corporation resident in Canada qualify as "excluded property", as that term is defined in subsection 95(1) of the Income Tax Act (the "Act"), of another foreign affiliate ("FA1") of the corporation. ... Our comments The relevant part of the definition "excluded property" in subsection 95(1) reads as follows: "excluded property", at a particular time, of a foreign affiliate of a taxpayer means any property of the foreign affiliate that is (a) used or held by the foreign affiliate principally for the purpose of gaining or producing income from an active business carried on by it, (b) shares of the capital stock of another foreign affiliate of the taxpayer where all or substantially all of the fair market value of the property of the other foreign affiliate is attributable to property, of that other foreign affiliate, that is excluded property, […] Pursuant to paragraph (b) of that definition, the shares of FA2 will qualify as excluded property of FA1 if all or substantially all of the fair market value of FA2's property is attributable to property that is excluded property. ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C) CRA Tags 94(3) Principal Issues: Can a non-resident trust that is subject to "new" subsection 94(3) deduct an amount under subsection 91(5) in respect of a FAPI inclusion resulting from the application of "old" clause 94(1)(c)(i)(C)? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2015-059849 91(5) Deduction – Non-Resident Trust Subject to “Old” Clause 94(1)(c)(i)(C) This letter is in reply to correspondence received from XXXXXXXXXX, an International Tax Auditor with the XXXXXXXXXX Tax Services Office, on July 14, 2015, wherein she requested our assistance in respect of the possible application of subsection 91(5) to a particular situation involving a non-resident trust. ... Comments The relevant portions of “old” subparagraph 94(1)(c)(i) read as follows: (i) the trust is deemed for the purposes of this Part and sections 233.3 and 233.4 to be a person resident in Canada no part of whose taxable income is exempt because of section 149 from tax under this Part and whose taxable income for the year is the amount, if any, by which the total of (…) (C) the amount, if any, by which the total of all amounts each of which is an amount required by subsection 91(1) or (3) to be included in computing its income for the year exceeds the total of all amounts each of which is an amount deducted by it for that year under subsection 91(2), (4) or (5), and Based on the wording of “old” clause 94(1)(c)(i)(C), the FAPI-Inclusions consist of net amounts of inclusion resulting from the application of subsections 91(1) or (3), and subsections 91(2), (4) or (5), as the case may be, in computing NRT’s income for its 2002, 2004 and 2006 taxation years. ...

12 January 2022 Internal T.I. 2021-0920371I7- METC – Cost of a cast Unedited CRA Tags Section: 118.2; paragraphs 118.2(2)(i) and (m), paragraph (i) of Regulation 5700 Principal Issues: Whether the cost of a walking cast would qualify as an eligible medical expense for the purposes of the METC. ... January 12, 2022 Marie-Pier Valiquette Income Tax Rulings Directorate A/Senior Programs Officer, Business and Employment Division Sales Tax and Benefits Information Cynthia Underhill Section, ABSB 2021-092037 Medical expense tax credit – eligibility of a walking cast We are writing in response to your email dated December 8, 2021, asking if the cost of a walking cast would qualify as a medical expense for purposes of the medical expense tax credit (“METC”), under section 118.2 of the Income Tax Act (Act). ... Section 5700 of the Regulations states: “[Prescribed device or equipment] — For the purposes of paragraph 118.2(2)(m) of the Act, a device or equipment is prescribed if it is a... ...

7 January 2009 Internal T.I. 2008-0304901I7- Taxation & Insolvency Unedited CRA Tags 164(1) Principal Issues: Whether all post-bankruptcy refunds vest automatically in a trustee in bankruptcy. ... Diegel & Feick Inc. (1980), 35 C.B.R. (N.S.) 309 (Ont. S.C.); Re Sihler (1982), 43 C.B.R. ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan CRA Tags 6(1)(f) 54 "capital property" 248(1) property 5(1) 6 39(1)(a)(iii) Principal Issues: 1. ... July 8, 2013 Trust Accounts Programs Division Income Tax Rulings Directorate Taxpayer Services and Debt Business and Employment Division Management Branch Kathryn McCarthy Attention: Marlene Sylvest 2012-047002 Settlement of Future Benefits – Administrative Services Only Plan We are writing in response to your e-mail of November 13, 2012, concerning an employer's group disability plan which is administered by an arm's length plan administrator ("administrator") on an administrative services only ("ASO") basis. ...

6 March 2015 Internal T.I. 2014-0553481I7- Taxable benefit – cell phones CRA Tags 6(1)(a) 6(1)(b) Principal Issues: Where an employer pays part of the cost of an employee's cell phone voice and data plan, whether the reimbursement is considered a taxable benefit for the employee under paragraph 6(1)(a). ... XXXXXXXXXX 2014-055348 March 6, 2015 Dear XXXXXXXXXX: Re: Taxable benefit – cell phones We are writing in response to your e-mail of October 21, 2014, and our conversations of January 6 (McCarthy/XXXXXXXXXX), and February 26, 2015 (McCarthy/XXXXXXXXXX), concerning the tax implications under the Income Tax Act ("Act") for certain employees of the XXXXXXXXXX ("Employer"), who use their personal cell phones to perform their employment duties. ...