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15 January 2004 Internal T.I. 2003-0026827- Non-resident & Tuition & Educations credits-- summary under Section 118.9 Summary Under Tax Topics- Income Tax Act- Section 118.9 no ability of child to transfer the credit where she was a non-resident with no Cdn. source of income A Canadian-resident father is claiming tuition and education tax credits transferred under s. 118.9 from his non-resident daughter who has been living with her mother in the U.S. since the couple’s divorce and has now been attending university in the U.S. ... The Directorate stated: Based on the line of reasoning in Oceanspan … and other cases … an individual who is not resident in Canada and who has no Canadian source income would not be entitled to the tuition and education tax credits. The individual is not liable to pay tax in Canada, and therefore has no need to utilize the provisions permitting the tax credits. … If the daughter was required to compute tax payable under Part I of the Act, then we agree that she would be entitled to the tuition tax credit under section 118.5 of the Act, assuming she otherwise qualified. … These credits, then, would be eligible for transfer to her father under the rules in sections 118.81 and 118.9. ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Clause 95(2)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) application of current use test under s. 20(1)(c) FA Finco, a foreign affiliate of Canadian Parent, lends money to FA Acquireco LLC (a US fiscally-transparent subsidiary of FA Holdco (which is a non-transparent Delaware subsidiary of Canadian Parent) to acquire all the shares of FA Target LLC (also fiscally transparent), which is merged into FA Acquireco LLC (renamed “Mergeco LLC”). ... Since Mergeco is a disregarded entity, Reg. 5907(1) – earnings – (a)(iii) requires such earnings to be computed under Part I for such purposes. This wording engages the current use test under s. 20(1)(c) – which should be satisfied since the Mergeco property would be used in an active business. ...

3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan-- summary under Private Health Services Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan a health spending account for a single shareholder/employee likely does not qualify as a PHSP Can a health spending account (HSA) (under which an employer agrees to reimburse its employees’ hospital and medical expenses incurred during the year up to a pre-determined limit) established for a single shareholder/employee (and family members) qualify as a private health services plan (PHSP)? CRA responded: [F]or a plan to be a PHSP … the plan must be a plan of insurance. ... Therefore, it … would likely not constitute a plan in the nature of insurance and consequently, would not qualify as a PHSP. ...

6 February 2014 External T.I. 2013-0512191E5- Mining Activities and SR & ED-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development CEE excluded even if renounced An expenditure incurred by a resource corporation which qualifies as Canadian exploration expense cannot be a qualified expenditure in respect of SR&ED by virtue of para. ...

3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) single shareholder/employee HSA does not qualify S. 6(1)(a)(i) excludes a taxable benefit from the employer’s funding of a private health services plan (PHSP) for its employees, including in the case of a health spending account (HSA) (under which an employer agrees to reimburse its employees’ hospital and medical expenses incurred during the year up to a pre-determined limit). ... This is based on its view that “for a plan to be a PHSP … the plan must be a plan of insurance” and, here, “[e]ffectively, the sole employee-shareholder is paying for the personal hospital and medical expenses for themselves and their family members through their solely owned corporation without any risks being assumed by the corporation.” ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Subsection 5903.1(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 5903.1- Subsection 5903.1(1) FACL carryback from transitional year In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ... " See summaries under Reg. 5901(2)(b) and Reg. 5907(1) – net earnings. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Subsection 220(3.2) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.2) no relief for late-filed Reg. 5901(2)(b) election A Reg. 5901(2)(b) election, to have a dividend treated as paid out of pre-acquisition surplus, must be made by the filing-due date for the taxation year in question, even where CRA subsequently assesses the year in question so as to change the relevant surplus balances. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Regulation 600 Summary Under Tax Topics- Income Tax Regulations- Regulation 600 no relief for late-filed Reg. 5901(2)(b) election A Reg. 5901(2)(b) election, to have a dividend treated as paid out of pre-acquisition surplus, must be made by the filing-due date for the taxation year in question, even where CRA subsequently assesses the year in question so as to change the relevant surplus balances. ...

7 February 1994 External T.I. 9309865 F- 6363-1 Foreign Affiliates / Cross-shareholdings / Surplus-- summary under Subsection 5902(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 5902- Subsection 5902(2) Where a corporation resident in Canada owns 95% of the common shares of FA1 which, in turn, owns 100% of the common shares of FA2 which, in turn, owns 5% of the commons shares of FA1, and the Canadian corporation disposes of its shares of FA1 to a third party and elects under s. 93(1), FA2 will be the particular foreign affiliate for the purposes of Regulation 5902(2)(a). ...