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19 November 2021 Roundtable, 2021-0914351C6- 2021 TEI Conference – Q3(b)(i) – Form T2200 Unedited CRA Tags 8(1)(i)(iii), 8(2), 8(10), 8(13), 67 Principal Issues: How the employer should complete the answers to Question 10 on Form T2200 in the case where an employee has the option to work from home and that time is not tracked by the employer? ...

21 April 1997 External T.I. 9707215 F- % coproduction differe % cout production Unedited CRA Tags 125.4 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principales Questions: 125.4- % coproduction differe % participation depense Position Adoptée: De façon générale, le CI pour une société admissible correspond à 25% de sa "dépense de main-d'oeuvre admissible". ...

22 May 1992 Income Tax Severed Letter 9214997- Old at-risk rules — administrative position — Signum case Unedited CRA Tags 96(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... This led to Appeal's Decision # 89-9R dated July 9, 1991 which stated that the FCA's decision was final and binding and that any outstanding objections or appeals held in abeyance pending the outcome of this appeal must be processed. ...

15 December 2006 External T.I. 2006-0182471E5 F- Intérêts " explicitement identifiés " Unedited CRA Tags 12(1)c) Principales Questions: Demande de précision concernant la position administrative de l'Agence du revenu du Canada énoncée dans les Nouvelles techniques no 30 où cette dernière utilise l'expression " intérêts explicitement identifiés ". ...

27 January 1992 Income Tax Severed Letter 9133105- Social assistance payments — employee contractor — Respite Caregivers of the Province of Manitoba Unedited CRA Tags 56(1)(u), 56(1)(u)(iii) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

22 September 1993 External T.I. 9304130- Direct ou indirectement — Fusion ou liquidation — Papillon Unedited CRA Tags 55(3)(b) SESSION SPÉCIALE DE L'APFF: 55(2) ET 55(3) DE LA LOI ETTRANSACTIONS PAPILLONSAPFF — 10 février 1993 Question 32 Il appert que Revenu Canada, Impôt a récemment donné une décision anticipée favorable lorsque dans le cadre d'une réorganisation papillon, la filiale de la corporation bénéficiaire du transfert est fusionnée plutôt que liquidée. ...

8 May 2012 Roundtable, 2012-0435731C6- CALU CRA Roundtable – May 2012 – Question 5 Unedited CRA Tags ITR 8304(10), 8503(26) Principal Issues: 1. ... CALU CRA Roundtable – May 2012 Question 5 – Individual Pension Plans (IPPs) Background The 2011 federal budget contained two proposals that affect certain defined benefit IPPs. ... The IPP PSPA calculation is determined using the formula A – B. Variable A is the greater of two amounts, described in paragraphs (a) and (b) respectively. ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D) Unedited CRA Tags Clauses 95(2)(a)(ii)(B) and (D), paragraph 20(1)(c), subsection 5907(1) of the Income Tax Regulations Principal Issues: How the current use approach would apply in analyzing clauses 95(2)(a)(ii)(B) and (D) to two specific examples. ...

7 November 1991 Income Tax Severed Letter- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d), 127(11.1) Dear Sirs: Re: Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes: * will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act; * will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and * will not reduce the amount of capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the amount of the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ... Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes: * will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act; * will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and * will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election CRA Tags ITR 5901(2.2) S.79 of Bill C-48 ITR 5901(2.1) ITR 5901(2)(b) 95(1) foreign accrual property income Principal Issues: 1) Do the surplus pools of a given CFA have to be adjusted as a result of a FACL carryback against the TCG portion of the FAPI inclusion reported in a previous year? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2014-056081 FACL carryback – Surplus implications, PAS election & application of Bill C-48 transitional rules This is in reply to your correspondence of December 8, 2014, wherein you requested our assistance in respect of the surplus implications of a "foreign accrual capital loss" ("FACL") carryback in the context of a given set of facts. ... The relevant part of paragraph 79(2)(a) of Bill C-48 reads as follows, as modified to incorporate the relevant deadlines that would be applicable in the context of the facts submitted (see text underlined): (…) if the corporation (…) elect in writing under this paragraph in respect of all of their respective foreign affiliates and file the election with the Minister of National Revenue on or before the day that is the later of (…) the filing-due dates for their taxation years that include the day on which this Act receives royal assent [June 30, 2014] and the day that is one year after the day on which this Act receives royal assent [June 26, 2014], subsections 5901(2) to (2.2) of the Regulations, as enacted by subsection (1), apply to dividends paid after December 20, 2002 by all the respective foreign affiliates of the elector corporations (…) In the context of the present case, the election for the PAS election rules to apply to the 2010-Dividend would have to have been made on or before June 30, 2014. ...