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6 November 2003 External T.I. 2003-0039525 F- Canadian Renewable & Conservation Expenses-- summary under Subparagraph (d)(viii) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 43.1- Paragraph (d)- Subparagraph (d)(viii) computers used in operating landfill biogas site might be Class 10 property, and applications software would be Class 43.1 or Class 12 property/ below-surface pipes would not qualify A corporation implementing a Canadian renewable and conservation expenses (CRCE) project that uses landfill sites, and injects them with bacteria to produce recoverable gas, puts a structure (pipes) into the ground to recover the gas. ... (d)(viii) of Class 43.1 then referred only to above-ground equipment, CCRA stated: Expenses of a capital nature incurred in respect of property that is not surface equipment (e.g., equipment buried in the ground) would not be covered by subparagraph (d)(viii) …. ... CCRA responded: [S]ubparagraph (d)(viii) of Class 43.1 … specifically excludes property otherwise included in Class 10. ...

27 March 2018 Internal T.I. 2017-0691941I7 F- Investissement frauduleux – Fraudulent Investment-- summary under Subparagraph 20(1)(p)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(p)- Subparagraph 20(1)(p)(i) Ponzi scheme investors can generally write off their reinvested interest income in the year the perpetrators are charged Individuals had “invested” in what turned out to be a Ponzi scheme under which for many years they paid income taxes on interest reported as being earned by them, with such interest being reinvested. ... The Directorate indicated that because various of the taxation years were before the 10-year period, they could not be so reassessed – and, in any event, the interest had been required to be recognized in the years in which the individuals received or were entitled to receive it. The Directorate went on to indicate that potential relief could be provided though a subsequent bad debt deduction – likely, in the year in which the promoters were charged. ...

2 April 2019 Internal T.I. 2016-0649821I7 F- Unclaimed superannuation or pension benefits-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amount received in Year 2 in lieu of pension benefit includes source deductions in Year 1 Although CRA usually applies its constructive receipt concepts in the context of employment income recognition, it has applied that concept to pension income recognition under s. 56(1)(a)(i). ... Its reasoning was that the amount could not be considered to be “received” as a pension benefit in the year of payment by the RPP administrator to the Directorate because the right-holder had not yet been identified – whereas in the subsequent year of payment over by the Directorate to the right-holder, that right-holder is receiving that amount under s. 56(1)(a)(i) as being “in lieu of” a superannuation or pension benefit. ...

15 May 2019 IFA Roundtable Q. 3, 2019-0798741C6- Participating Debt Interest & US Treaty-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 contingent interest under Art. XI(6)(b) of the US Treaty does not taint contemporaneous fixed interest 2016-0664041R3 dealt with a term loan which included both periodic non-participating interest payments, as well as future additional payments (the “Additional Amounts”) that were contingent on the index price of a particular commodity, and ruled that the former were not “participating debt interest” if, at or before the time of each payment thereof, no Additional Amount had been paid or become payable – but that all payments of periodic non-participating interest would be considered to be “participating debt interest” subject to withholding tax once an Additional Amount was paid or became payable. Unlike the definition in the Act of “participating debt interest,” which refers to an interest payment “... all or any portion of which interest is contingent or dependent...”, the Canada-US Treaty definition of contingent interest in Art. ...

26 November 2020 STEP Roundtable Q. 13, 2020-0847201C6- GRE & section 216 election-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) a non-resident estate (using GRE graduated rates), then its residuary beneficiaries, could file under s. 216 respecting a Canadian rental property A non-resident individual owning a Canadian rental property had filed T1 returns pursuant to the s. 216 rules. ... While the Estate is a GRE, the Estate will be taxed at the graduated rates in respect of the net rental income.... … Provided that the section 216 requirements are satisfied, from the time they acquire beneficial ownership of the property, Y and Z could elect to file under Part I pursuant to section 216 in respect of their share of income derived from the rental property. … ...

3 December 2024 CTF Roundtable Q. 11, 2024-1038241C6- Global Minimum Tax Act – Interpretation and Application of OECD Agreed Administrative Guidance-- summary under Subsection 17(6) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Global Minimum Tax Act- Section 17- Subsection 17(6) CRA will administer s. 17(6) to push down taxes paid by indirect owner of reverse hybrid CE on income of the CE allocated to it, to the CE CRA indicated that as new OECD administrative guidance is released, the DST and Global Tax Section of CRA will consult with the Department of Finance to determine, on a case-by-case basis, how such guidance should be handled – whether there is a pending amendment to the Global Minimum Tax Act (GMTA) or whether CRA will apply the new guidance to inform its interpretation of the existing GMTA provisions. ... CRA indicated that it has consulted with Finance and, in light of likely further amendments, it will administer the provisions of the GMTA to achieve what the OECD administrative guidance clarifies should be the outcome – that is, the constituent entity covered taxes paid by the upper-tier entity being pushed down to the CE. ...

26 November 1992 T.I. 923506 (September 1993 Access Letter, p. 411, ¶C20-1161)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt For farmers on the cash method, a post-dated cheque that is received on a date that a debt owing to the taxpayer is not yet payable will be brought into income on the earlier of the date the debt becomes payable and the date the cheque is negotiated. ...

11 December 2013 External T.I. 2013-0474161E5- T-slips and dividend and interest-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt Respecting a question as to when dividends are paid and received for T5 purposes, CRA stated: In Innovative Installation Inc. v The Queen, 2009 TCC 580, the Tax Court of Canada explained that "received" does not require "proceeds to pass directly to the taxpayer. ...

6 November 2012 External T.I. 2012-0452531E5- Satisfactory Evidence of Payment-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note accepted as payment In response to a question as to whether "a demand note payable, which is accepted as absolute payment of salary owing to an employee, constitutes satisfactory evidence of the payment of that salary," CRA stated: An ordinary promissory note is generally regarded as a promise to pay a debt at a later date, and not as payment of the debt on the date on which the note was issued. ...

17 June 2014 External T.I. 2013-0506731E5- Immigration-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt note satisfied dividend An individual shareholder immigrates to Canada, thereby becoming a Canadian resident. ...