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Bundle Date Translated severed letter Summaries under Summary descriptor 2023-10-11 24 January 2023 External T.I. 2018-0753471E5 F- Supplément remboursable pour frais médicaux Income Tax Act- Section 122.6- Adjusted Income adjusted income does not include income of spouse who died in the year 9 June 2017 External T.I. 2017-0700961E5 F- Retenues à la source Income Tax Regulations- Regulation 100- Subsection 100(3)- Paragraph 100(3)(c) no withholding where RCA pays retiring allowance to RRSP that is an s. 60(j.1) eligible amount or within the RRSP deduction limit 2002-10-25 5 November 2002 External T.I. 2002-0160815 F- CDC HYPOTHEQUE Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (d) change in policy re CDA credit for life insurance proceeds paid to creditor is retroactive re the computation 7 November 2002 External T.I. 2002-0168795 F- REER TRANSFERT D'ACTIONS AU RENTIER Income Tax Act- Section 146- Subsection 146(8) shares can be distributed out of RRSP to annuitant – but with their FMV being included as a benefit 14 November 2002 Internal T.I. 2002-0171377 F- REER PLACEMENT ADMISSIBLE Income Tax Act- Section 204- Qualified Investment- Paragraph (a) money means currency 14 November 2002 External T.I. 2002-0136485 F- REVENU D'ENTREPRISE ET REVENU DE BIEN Income Tax Act- Section 129- Subsection 129(4)- Income or Loss long-term rental of excess space unlikely to be assimilated to business income 21 November 2002 External T.I. 2002-0141455 F- TITRES DETENUS PAR UN FIDUCIAIRE Income Tax Act- 101-110- Section 108- Subsection 108(1)- Trust- Paragraph (a.1) exclusion of s. 7(2) trusts for greater certainty 30 October 2002 Internal T.I. 2002-0146787 F- PRET SANS INTERET A UNE FILIALE Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest incurred to make interest-free loans to non-resident subsidiary was deductible if an expectation of income from its shares ...

& Disc. Div. Shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) payment of dividends on discretionary dividend shares with no liquidation entitlement would not result in a significant reduction 30 October 2002 External T.I. 2002-0126045 F- TRANSFERT A UN MINEUR Income Tax Act- Section 248- Subsection 248(1)- Specified Member contributions of the specified member to the partnership business must be instrumental to its success ...

In summarized form, the list now consists of: A taxpayer buys an interest in a partnership which, immediately prior thereto, had realized the gain legs on straddle transactions in FX forward contracts (with such gain allocated to the selling partner) – and with the loss legs then being realized and allocated to the taxpayer. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-09-13 4 October 2002 Internal T.I. 2002-0139807 F- REMBOURSEMENT DE TPS Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- J GST rebate received after sale of asset would not, under J of UCC formula, produce recapture Income Tax Act- Section 13- Subsection 13(7.1) GST rebate claim reduced UCC pursuant to J of formula rather than under s. 13(7.1, since claimed after asset’s disposition Income Tax Act- Section 6- Subsection 6(8)- Paragraph 6(8)(b) GST rebate claimed by employee re CCA on car after its sale reduces UCC pursuant to J of formula rather than under s. 13(7.1) 4 October 2002 Internal T.I. 2001-010564A F- PENSION ALIMENTAIRE-ARRERAGES Income Tax Act- Section 60- Paragraph 60(b) lump sum payment in settlement of periodic support payments in arrears is an amount payable on a periodic basis General Concepts- Payment & Receipt set-off does not constitute payment unless the parties so agree 2 October 2002 External T.I. 2002-0118815 F- DIABETE JUVENILE Income Tax Act- Section 118.3- Subsection 118.3(1)- Paragraph 118.3(1)(a.1) child with juvenile diabetes does not generate the infirm credit, including under para. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2023-11-29 4 October 2023 Internal T.I. 2020-0837811I7 F- Suspended loss Income Tax Act- Section 40- Subsection 40(3.5)- Paragraph 40(3.5)(c)- Subparagraph 40(3.5)(c)(i) suspended loss rule continued to apply when the transferee was amalgamated, then wound-up into the transferor 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 2002-07-19 6 August 2002 Internal T.I. 2002-0130897 F- RECOMPENSES ES QUASI-MONETAIRES Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(l)- Subparagraph 18(1)(l)(ii) s. 18(1)(l)(ii) applies irrespective whether the membership is an employer gift within the ITTN 25 gifts policy Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) gift cards and smart cards with spendable balances do not come within the ITTN 25 gifts policy Income Tax Act- Section 67.1- Subsection 67.1(2)- Paragraph 67.1(2)(d) s. 67.1(2)(d) exclusion inapplicable to meal or show ticket gifts within ITTN 25 gifts policy 9 August 2002 Internal T.I. 2002-0145817 F- TAUX DE DEDUCTION- PTPE- ANNEE 2000 Income Tax Act- Section 38- Paragraph 38(c) BIL realized under s. 50 at end of year (2000) so that ½ an ABIL 2 August 2002 External T.I. 2002-0152445 F- RENTE VIAGERE ET CREDIT Income Tax Act- Section 118- Subsection 118(7)- Pension Income- Paragraph (a)- Subparagraph (a)(i) an annuity that ceases upon attaining a specified age is not a “life annuity” 13 August 2002 External T.I. 2002-0121295 F- PBR DES PARTS PRIVILEGIEES Income Tax Act- Section 43- Subsection 43(1) sale of preferred and retention of common partnership units entailed part disposition of single property/ different s. 43 allocation methods possible Income Tax Act- Section 248- Subsection 248(1)- Property preferred and common partnership units were single property 6 August 2002 External T.I. 2002-0130735 F- DISPOSITION D'UN PERMIS Income Tax Regulations- Schedules- Schedule II- Class 14 licence to operate a seniors home was eligible capital property whereas related agreements with Ministry (that after a point were not automatically renewable) were Class 14 property 2002-07-05 31 July 2002 External T.I. 2002-0153135 F- FRAIS JUDICIAIRES Income Tax Act- Section 60- Paragraph 60(o.1) amounts incurred by retiree association in suing pension fund not deductible under s. 60(o.1) unless incurred as agent for retirees ...

These are additions to our set of 2,676 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 21 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,688 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 21 ½ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-05-24 6 June 2002 External T.I. 2002-0133895 F- entreprise de placement determinee Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business recapture from sale of a rental business qualified as business income that was not from a specified investment business, notwithstanding no employees in that year after the sale Income Tax Act- Section 13- Subsection 13(1) recapture is treated as income from the business in which the depreciable asset was used 27 May 2002 External T.I. 2002-0135605 F- DIVISION 6208(1)a)(iii)(A) du Règlement Income Tax Regulations- Regulation 6208- Subsection 6208(1)- Paragraph 6208(1)(a)- Subparagraph 6208(1)(a)(iii) meaning of “other property” informed by s. 248(1) meaning of “property” 10 June 2002 External T.I. 2002-0138885 F- Redemption of Preferred Shares Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a) s. 55(3)(a) applicable to redemption by Opco of preferred shares held by father’s holding company where Opco’s common shares held by his children or their Holdcos 4 June 2002 External T.I. 2002-0141435 F- Disposition of Shares Income Tax Act- Section 248- Subsection 248(1)- Disposition exchange of voting common for voting pref and non-voting common is a disposition Income Tax Act- Section 85- Subsection 85(1) exchange of voting common for voting pref and non-voting common eligible for s. 85(1) election 12 June 2002 External T.I. 2002-0143325 F- REGIME DE CONGE A TRAITEMENT DIFFERE Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(ii) combined application of 33 1/3% limit where 2 SDAs Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(iii) where 2 SDAs, combined application of reduction under Reg. 6801(a)(iii)(A) 24 May 2002 Internal T.I. 2002-0130667 F- REGIME PRESTATION EMPLOYES Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement discussion of transitional rules re expansion of SDA rules effective February 26, 1986 Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(g) amounts received by retiring employee under EBP even if elected not to receive General Concepts- Payment & Receipt amounts “received” under EBP if unrestricted right to receive ...

Summary of 2022 Ruling 2020-0859851R3 under s. 95(1) – foreign accrual tax. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2024-01-31 2023 Ruling 2022-0955451R3 F- Post mortem pipeline Income Tax Act- Section 84- Subsection 84(2) conventional post-mortem pipeline transaction 22 June 2023 External T.I. 2018-0746741E5 F- Eligible dividend allocation Income Tax Act- 101-110- Section 104- Subsection 104(19) eligible and non-eligible dividend can be wholly designated to two respective beneficiaries Income Tax Act- 101-110- Section 104- Subsection 104(13) a discretionary trust can wholly allocate each of an eligible and a non-eligible dividend to each of two recipient beneficiaries 2002-04-26 22 May 2002 Internal T.I. 2001-0106577 F- APPARIEMENT DES REVENUS ET DEPENSES Income Tax Act- Section 9- Timing following Canderel, an upfront payment made under a multi-year supply contract is currently deductible 14 May 2002 Internal T.I. 2001-0109517 F- SECTION DE LA LOI248(28) Income Tax Act- Section 248- Subsection 248(28) disallowance of interest deduction to partnership on loans to corporate partners whose amount was included in their income under s. 15(2), was not contrary to s. 248(28) 8 May 2002 Internal T.I. 2002-0135737 F- REGIME DE CONGE A TRAITEMENT DIFFERE Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(vi) s. 6(11) income recognition when apparent that the leave would not commence within 6 years/ Reg. 6801(a)(vi) does not to extend 6-year period but deals with leaves over one year 2002-04-12 3 May 2002 External T.I. 2001-0110145 F- avantage imposable-vetements Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) reimbursing a professor for a briefcase needed in connection with work would be non-taxable 3 May 2002 External T.I. 2002-0132615 F- PERTE DECOULANT D'UN PAIEMENT A UN RPDB Income Tax Act- Section 147- Subsection 147(8) creation of a business loss from making a DPSP contribution is not necessarily inconsistent with the DPSP rules 1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home ...