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" The subsequent memo (without explanation) stated: [W]e are no longer of the view that the interest received on Note 2 should be included in the FAPI of NR1.... ...

XXIV, para. 2 and 3 of the Canada-U.S. Income Tax Convention, a portion of the income from Canco'’s Canadian XX business must be re-sourced to the U.S. for the purposes of section 126 of the Act. ...

25 September 2013 External T.I. 2013-0477571E5 F- Partnership- fin. fees and mng fees-- summary under Subsection 402(7) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(7) service performed by service to partnership must have been previously performed by a partnership employee and relate to a short-term task A partnership (P1), whose sole permanent establishment is in Province 1, is a member of two partnerships (P2 and P3) whose sole permanent establishment is in Province 2 and 3, respectively. ...

XXIV, para. 2 and 3 of the Canada-U.S. Income Tax Convention, a portion of the income from Canco’s Canadian XX business must be re-sourced to the U.S. for the purposes of section 126 of the Act. ...

24 June 2015 External T.I. 2015-0575911E5 F- Benefit to shareholder or conferred on a person-- summary under Paragraph 15(1.4)(c) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1.4)- Paragraph 15(1.4)(c) benefit only conferred on one shareholder (the husband) if wife of one of four sibling shareholders receives benefit Corporation A, which has equal unrelated Shareholders 1, 2, 3 and 4, disposes of a capital property to the spouse (who is not herself a shareholder) of Shareholder 4 at a price which is determined to be less than the property's fair market value. ...

After noting that IT-223 (archived), para. 2 still represented CRA policy, CRA stated (TaxInterpretations translation): [T]he Credit Card Insurance accords the right to a fixed monthly amount for XXXXXXXXXX years irrespective of the amount of the actual overhead expenses incurred or paid by the corporation during the period of disability of the shareholder. ...

Credit Card Insurance After noting that IT-223 (archived), para. 2 still represented CRA policy, CRA stated (TaxInterpretations translation): [T]he Credit Card Insurance accords the right to a fixed monthly amount for XX years irrespective of the amount of the actual overhead expenses incurred…by the corporation during the period of disability of the shareholder. ...

23 October 2012 External T.I. 2011-0431301E5- Meaning of Substantial Operation-- summary under Article 8 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 8 CRA was asked whether an operation that provides temporary services, for a period of less than six months, constitutes a "substantial operation" for purposes of Art. 8, para. 2 of the Canada-Sweden Convention. ...

Rulings: Each Investor's interest in the Foreign Partnership will be taxable Canadian property Such interest will be treaty-protected property for Investors resident in Foreign Countries 1 through 4 provided stipulated conditions relevant to the applicable Treaty are satisfied, as follows: Treaty 1- the only properties of the Foreign Partnership are the shares of Foreign Parent, the Foreign Parent Loans and the Foreign Subsidiary Loans Treaty 2 – the Investor does not have a controlling interest, (a controlling interest being where the Investor and persons related to the Investor have an interest of 50% or more), in the Foreign Partnership Treaty 3 – no additional conditions Treaty 4- the Investor and any persons related to or connected with the Investor are entitled to an interest of less than 10% of the income and capital of the Foreign Partnership immediately before the Disposition Time Treaty 5- not treaty-protected property ...

Proposed transactions: The Estate will transfer its Class A and C shares to a newly-incorporated corporation (Newco), whose common shares are owned equally by X, Y and the Trust, in consideration for two Notes Y and Z will transfer their common and Class B shares, and the Trust will transfer its common share, of Amalco to Newco in consideration for non-voting preferred shares of Newco Amalco will be amalgamated with Newco no sooner than one year after the above transfers The Notes "will be gradually repaid over a period of at least one year after the amalgamation date, but the amount of the repayments in any given quarter of that year will not exceed X% of the principal amount of Note 1 and Note 2 when they were issued" Rulings: S. 84.1 will not apply to the transfer of shares by the Estate to Newco for the Notes, except that it will so apply to the extent of the V-Day value of the Class A shares so transferred by it S. 84(2) will not apply to deem the Estate to have received a dividend on the Class A and C shares ...