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These are additions to our set of 1,029 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¾ years of releases of Interpretations by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-02-25 8 October 2010 Roundtable, 2010-0373161C6 F- Paragraphs 256(3) and 256(6) ITA Income Tax Act- Section 256- Subsection 256(6) application could prevent acquisition of control or preclude loss of CCPC status 8 October 2010 Roundtable, 2010-0373191C6 F- Computation of safe income Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) where interest in partnership holding Subco with safe income is rolled into Holdco for prefs, dividends from Subco do not change consolidated SIOH of prefs – or increase commons’ SIOH 2011-02-18 8 October 2010 Roundtable, 2010-0373131C6 F- Présomption d'action concertée Income Tax Act- Section 251.2- Subsection 251.2(2)- Paragraph 251.2(2)(a) Q of fact re whether 3 or more CCPC shareholders form a group 9 December 2010 Internal T.I. 2010-0371741I7 F- Automobiles mises à la disposition des employés Income Tax Act- Section 248- Subsection 248(1)- Automobile qualification as automobiles turns on design, not use Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(e) employer-provided automobile to attend occasional off-site meetings did not generate a benefit 24 January 2011 Internal T.I. 2010-0389251I7 F- Farm-out agreement and warrants Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (j) CEE to be incurred under simple farmout reduced by an allocation to warrants issued by farmee Income Tax Act- Section 15- Subsection 15(1) valuation of “free” warrants issued as part of a simple farmout agreement determined based on what would be a s. 15(1) benefit General Concepts- Fair Market Value- Options amount allocated out of consideration to “free” warrants based on the greater of their trading and in-the-money value Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) application of farmout policy to situation where free warrants issued along with incurring of CEE ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-01-28 5 January 2011 Internal T.I. 2010-0389761I7 F- Application du paragraphe 162(7.01) Income Tax Act- Section 162- Subsection 162(7.01) s. 162(7.01) penalty is cumulative with (7.02). and is computed aggregating base and summary slips and both are computed from initial final deadline if s. 220(3) deadline is missed 2011-01-07 1 December 2010 External T.I. 2010-0385491E5 F- Postes isolés dans la fonction publique Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan employer agreement to pay transportation costs from remote location re medical appointments could qualify as an exempt PHSP 2010-12-31 9 December 2010 External T.I. 2010-0364001E5 F- Ristourne de consommation, feuillet T4A Income Tax Act- Section 135- Subsection 135(7) no income inclusion re consumer goods or services Income Tax Regulations- Regulation 218 T4A required where annual payments in proportion to patronage exceed $500 2010-12-24 7 December 2010 External T.I. 2010-0363431E5 F- Date limite cotisation REER Income Tax Act- Section 146- Subsection 146(5) 60-day contribution deadline is met based on receipt of cheque by issuer, not its deposit General Concepts- Payment & Receipt RRSP premium “paid” when cheque received by issuer, not when it’s deposited 9 December 2010 External T.I. 2010-0388101E5 F- CCPC status and acquisition of control Income Tax Act- Section 249- Subsection 249(4)- Paragraph 249(4)(b) CCPC whose control has been agreed to be acquired by Pubco can elect to extend its deemed s. 249(3.1) year end under s. s. 249(4)(b) Income Tax Act- Section 249- Subsection 249(3.1) CCPC which has a December 26 deemed year end under ss. 249(3.1) and 251(1)(b) that is extended to December 31 under s. 249(4)(b) loses SBC for that extended year ...

These are additions to our set of 1131 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 ¼ years of releases of Interpretations by the Directorate. ...

These are additions to our set of 1,147 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 ½ years of releases of Interpretations by the Directorate. ...

These are additions to our set of 1,169 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 ¾ years of releases of Interpretations by the Directorate. ...

These are additions to our set of 1,174 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 ¾ years of releases of Interpretations by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2020-06-17 2 June 2020 External T.I. 2020-0847081E5 F- Compte de frais médicaux – période de report Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan during COVID-19, unused HCSA credits can be carried forward for up to an additional 6 months 2010-06-25 11 June 2010 External T.I. 2010-0354881E5 F- Traitement fiscal de la FNACC Income Tax Act- Section 20- Subsection 20(16) ceasing to use a class of depreciable property to generate income results in a terminal loss under ss. 45(1)(a) and 20(16) Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(a) application of s. 45(1)(a) to film production that ceased to generate income, resulting in a terminal loss under s. 20(16) 2 June 2010 External T.I. 2010-0354951E5 F- Bien de remplacement-disp. involontaire Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(a.1) rental building did not qualify as a replacement property to an expropriated parking lot because of different physical attributes 2010-06-18 7 June 2010 External T.I. 2009-0331731E5 F- CII et crédit de taxe sur le capital du Québec Income Tax Act- Section 13- Subsection 13(7.2) Quebec ITCs or capital tax credits reduce the LP’s UCC at end of its October 31 fiscal period following the calendar year in which its partners claimed those credits 4 June 2010 External T.I. 2009-0324801E5 F- catégorie 43 Income Tax Regulations- Schedules- Schedule II- Class 43 potential inclusion of moulds and cranes, but not forklift truck 9 June 2010 External T.I. 2009-0342081E5 F- Associé déterminé Income Tax Act- Section 248- Subsection 248(1)- Specified Member trust member of partnership can be actively engaged through the activities of its trustee Income Tax Act- 101-110- Section 104- Subsection 104(1) s. 104(1) imputes the activities of the trustee to the trust for “specified member” purposes ...

These are additions to our set of 1,230 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 ¼ years of releases of Interpretations by the Directorate. ...

These are additions to our set of 1,236 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 ¼ years of releases of Interpretations by the Directorate. ...