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21 April 2008 Internal T.I. 2007-0251761I7 F- Billet à payer-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt addition of unpaid interest to principal was not a loan of money, nor a payment or crediting of interest Debt owing to the taxpayer following an asset sale provided that interest may be added to the principal of the debt, which is what occurred. In finding that the capitalized interest was not a separate loan of money, so that the interest thereon could only be deducted under s. 20(1)(c) rather than (d), CRA stated: The facts submitted did not show that there was an actual transfer of money, and that the “mere statement that an amount of interest was added to the principal of the original debt does not seem to us sufficient to conclude that there was a … [fresh] loan between the parties.” ...

11 October 2017 External T.I. 2016-0660421E5- Foreign tax credit – former resident-- summary under Subsection 126(2.21) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(2.21) waiver cannot be used to extend period in which foreign tax must be triggered Where an individual, who had been resident in Canada for over five years, realized a capital gain from the deemed disposition of non-Canadian real property under s. 128.1(4)(b) on emigrating from Canada, he would be potentially eligible under s. 126(2.21) to claim a Canadian foreign tax credit for foreign taxes that become payable on the gain that accrued in Canada, provided that this credit is assessed within the extended reassessment period of six years following the emigration year. ... CRA stated: [I]f any of the circumstances to support the deduction under subsection 126(2.21) … (e.g., disposition of the property and/or foreign taxes paid) are present within the statutory assessment period referred to in paragraph 152(4)(b) … it may be appropriate for the Minister to consider a taxpayer’s waiver request for the emigration year to allow the Minister sufficient time to review and process any potential reassessment for this deduction beyond the aforementioned reassessment period. ...

5 December 2017 Roundtable, 2017-0734831C6- 2017 TEI – Question B5-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) incomplete applications rejected/meeting within 4 weeks/90 business-day service standard made more flexible The Minister of National Revenue’s report to the Finance Committee dated May 29, 2017 indicated that a number of key changes would be implemented before the end of the year, being March 31, 2018, including the following: More frequent and better communications between the taxpayer and the CRA, including a meeting with taxpayers to be held no later than within four weeks of receipt of an ATR request. … Amend the current 90-day service standard for ATRs to address complex tax policy issues that cannot typically be completed within a 90-day period, namely, those that require a formal referral to the CRA’s General Anti-Avoidance Rule Committee, the Department of Finance or the Department of Justice. … Close an ATR file where the ATR request is not properly prepared or supported with adequate representations or where the taxpayer has not responded to a request for additional information within 30 calendar days. ...

27 March 2018 Internal T.I. 2017-0691941I7 F- Investissement frauduleux – Fraudulent Investment-- summary under Subsection 152(4.2) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4.2) s. 152(4.2) reversal of Ponzi interest inclusion must be applied for by 10th anniversary of the taxation year The “Investors” 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 in the case of the years beyond the normal reassessment period, by virtue of the s. 152(4.2) relief provisions, the Minister may “at the request of a taxpayer, reassess for any taxation year on or before the day that is 10 calendar years after the end of that taxation year,” so that, for example, “under the relief provisions, a taxpayer may request an adjustment to the taxpayer’s income tax return for the 2008 taxation year … by December 31, 2018.” ... " 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. ...

2018 Ruling 2018-0740931R3 F- deductibility of interest – convertible debentures-- summary under Subsection 20(3) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(3) s. 20(3) applicable to borrowed money used to redeem principal of convertible debentures A Canadian public company (ACo) will force the conversion of its outstanding convertible debentures, by issuing a notice to redeem them for their principal amount. ... It also ruled: Subsection 20(3) will be applicable to the portion of Loan 3 … corresponding to the aggregate principal amount of the outstanding Debentures … such that borrowed money will be deemed for purposes of the application of paragraph 20(1)(c) to be used for the purposes for which the outstanding Debentures were used or incurred. ...

22 February 2022 External T.I. 2022-0922921E5- CEWS, THRP, & HHBRP-- summary under Subsection 125.7(2.01) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(2.01) definitions of “company,” “publicly traded company,” and “subsidiary” CRA indicating regarding the interpretation of s. 125.7(2.01): “Taxable dividends” include taxable dividends that are deemed dividends. ... A “publicly traded company” is “a company the shares … of which are listed or traded on a stock exchange or other public market” and “would include [such] a non-resident company.” ... A “subsidiary” is “generally understood to be a corporation that is controlled by another corporation either directly or indirectly through one or more intermediary corporations [referencing s. 2(5) of the CBCA]” … and CRA “would consider a subsidiary of a publicly traded company to be a corporation over which the publicly traded corporation exercises de jure control either directly or indirectly.” ...

23 January 2023 External T.I. 2020-0865161E5 F- SSUC/CEWS – Sous-alinéa 125.7(4)e)(i) et personne-- summary under Paragraph 125.7(4)(e) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(4)- Paragraph 125.7(4)(e) electing taxpayer can receive amounts through third party where receipt on its behalf is established by agreement or statute Regarding the time at which an amount is regarded as received by an eligible entity which has made an election under s. 125.7(4)(e)(i) to use the cash method in determining its qualifying revenues for CEWS purposes, where the amount is received by a third party before being paid to the eligible entity, CRA stated: IT-433R … states [in subpara. 3(a)] that the meaning of the term "received" is broad enough to consider a taxpayer to have received an amount at the time that inter alia it was received by a person authorized to receive it on behalf of the taxpayer. … [A] person entitled to receive an amount on behalf of a taxpayer for CEWS purposes may include a person who is entitled to receive the amount for a taxpayer by inter alia an agreement or by statute. ...

3 December 2024 CTF Roundtable Q. 11, 2024-1038241C6- Global Minimum Tax Act – Interpretation and Application of OECD Agreed Administrative Guidance-- summary under Subsection 3(1) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Global Minimum Tax Act- Section 3- Subsection 3(1) CRA will consult with Finance re potential amendments to catch up to OECD guidance in administering the GMTA How will the Global Minimum Tax Act (GMTA) be administered in circumstances where its enacted state does not reflect changes to the GloBE Model Rules, or to new GloBE Commentary or Administrative Guidance? CRA indicated that, to apply the GMTA as intended, as new 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 potential legislative amendment or whether CRA will apply the new guidance to inform its interpretation of the GMTA. ... Therefore, CRA will administer the provisions of the GMTA to achieve what the 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 constituent entity. ...

18 November 2004 Internal T.I. 2004-0083251I7- Management Fees-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission General discussion of the distinction between rectification of mistakes and retroactive tax planning. ...

28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A taxpayer is not considered to have "paid" interest on a loan owing by him to a charitable foundation by virtue only of journal entries being recorded in his ledgers and those of the foundation. ...