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In finding that the partnership would not satisfy various requirements of IT-426R, para. 2 for use of the cost-recovery method, including the requirement of subpara. 2(f) that “[t]he vendor is... resident in Canada”- CRA stated: The definition of “Canadian resident partnership” … is not relevant for the application of [subpara. 2(f)] …. ...

17 May 2022 IFA Roundtable Q. 10, 2022-0926331C6- Corporate Residence Approach-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) board meeting situs not determinative of CMC Regarding a query as to whether CRA will continue to have “too much focus on the location of board meetings” in determining corporate residency, CRA noted that De Beers indicated that a corporation’s central management and control “must … be determined after a scrutiny of the whole ‘course of business and trading’ of the corporation,” and then stated: Usually, central management and control is considered to abide where the members of the board of directors meet to make important and strategic decisions regarding the affairs of the corporation, unless central management of control is actually exercised elsewhere. ...

Siblings 1 and 2 will each transfer his DC common shares on a s. 85(1) rollover basis to TC1 and TC2, respectively (each incorporated by the respective Sibling for one common share) solely in consideration for TC1 or TC2 common shares. ...

26 January 2023 External T.I. 2021-0887661E5- Small Business Deduction- Related-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Corporate Income- Paragraph (a)- Subparagraph (a)(i) 2 related but not associated CCPCs do not have their SBD ground under s. 125(1)(a)(i)(B) if they have no business dealings with each other Mr. ...

13 March 2023 External T.I. 2019-0802271E5 F- Déduction supplémentaire prévue au sous-alinéa 110-- summary under Paragraph 1100(1)(c.1) Summary Under Tax Topics- Income Tax Regulations- Regulation 1100- Subsection 1100(1)- Paragraph 1100(1)(c.1) transferring Class 14.1 property under s. 98(3) eliminates any additional Reg. 1100(1)(c.1)(i) CCA claims Regarding the availability of the additional deduction under Reg. 1100(1)(c.1)(i) where a Class 14.1 property was acquired by a taxpayer after December 31, 2016 as a result of a distribution of the property on an s. 98(3) rollover basis, CRA stated: [F[or taxation years ending before 2027, subparagraph 1100(1)(c.1)(i) allows a taxpayer to claim additional capital cost allowance of 2% on the portion of the undepreciated capital cost of Class 14.1 property at the beginning of January 1, 2017 that exceeds the total of the amounts described in clauses (A) and (B) of that subparagraph. ...

11 May 2023 Internal T.I. 2022-0936701I7- Interest on adj income by a loss carry forward-- summary under Subsection 161(1) Summary Under Tax Topics- Income Tax Act- Section 161- Subsection 161(1) no arrears interest would arise where non-capital loss carryforwards eliminated a tax payable balance arising from reassessments A taxpayer reported a capital loss in year 1 of $50 million, which was applied to offset a $1 million capital gain realized in year 1 and a $49 million capital gain realized in year 2. ...

The loan is repaid within 2 years so that the upstream loan rules in s. 90(6) do not apply. ...

The loan is repaid within 2 years so that the upstream loan rules in s. 90(6) do not apply. ...

4 October 2023 Internal T.I. 2020-0837811I7 F- Suspended loss-- summary under Paragraph 251.1(4)(a) Summary Under Tax Topics- Income Tax Act- Section 251.1- Subsection 251.1(4)- Paragraph 251.1(4)(a) corporation in its 2 capacities of transferor, and continuation of transferee, was affiliated with itself Aco disposed of its shares of Cco (the “Subject Shares”) at a loss to a wholly-owned subsidiary of Aco (Bco). ...

Consequently, the amount of Part XIII tax paid by Canco on behalf of Sisterco would not be included in computing the income of Sisterco under subsections 15(1) or (2) because, respectively, on the one hand, Sisterco is not a shareholder of Canco and, on the other hand, Sisterco would not be considered to a have received a loan from or become indebted to Canco. ...