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B), CRA (surprisingly) indicated that there would be no taxable benefit from such use by the father for the years under review before the effective date of s. 15(1.4)(c) – but thereafter, the value of the benefits enjoyed by the father were taxable to his son (Mr. ... As for the valuation of those benefits, CRA concluded after reviewing four Court of Appeal decisions (Youngman, Fingold, Schroter and Anthony) that the valuation of the benefits should be based on their fair market value (corresponding "to the price the user would have paid an independent corporation for a similar benefit") rather than their cost – although, here, the denied operating expenses and CCA of the corporate owner "can be used to establish the value of the benefit conferred on Mr. ...

27 December 2016- 9:18pm The expansion under s. 55(2.1)(b) of the scope of s. 55(2) has resulted in potential anomalies Email this Content Prior to the introduction of the new s. 55(2.1)(b), a Holdco could create a Subco with common shares having a fair market value equal to their adjusted cost base (by having Opco pay a stock dividend of pref shares with full paid-up capital and transferring those prefs to Subco for high basis shares of Subco) – and then have Subco declare a dividend to it of the Opco prefs, which reduces the FMV of Subco’s shares below their ACB but was not caught by the old s. 55(2) because the purpose of the dividend could not be to reduce a capital gain on the Subco shares. ... " 2015 CTF Annual Conference paper under s. 55(2.1)(b), s. 55(1) – safe income determination time, s. 55(2.3). ...

For example, Example 7 references a PSB that is charged at the Ontario rate of 13% on software programming services acquired by it for “use” 80% at its Ontario head office and 20% at one of its offices in PEI – and goes on to note that the PSB would be required to self-assess itself for the 2% higher PEI HST rate on the 20% portion for use in PEI, before then calculating its rebate. ... Does the absence of any burgeoning published policy signify that CRA is not attempting to enforce this provision, so that it is not developing any experience with it (maybe kind of like the GST GAAR – see Brent Murray)? ...

In 26 May 2016 IFA Roundtable Q. 6, 2016-0642081C6, CRA confirmed that, at least in the simple case where Parentco wholly-owns Subco through ownership of a single class of shares, the annual profit transfers will be deemed to be dividends under s. 90(2) and, thus, not foreign accrual property income to the direct or indirect Canadian parent of Parentco – and then indicated that this supplanted an earlier position (e.g., (e.g., 2001-0093903) that a profit transfer payment made by Subco to Parentco could be re-characterized as income from an active business of Parentco under s. 95(2)(a)(ii) to the extent that Subco had earnings from an active business before taking into account the profit transfer payment – so that this previous position will only apply to profit transfer payments made before 2017. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2014-12-10 10 October 2014 APFF Roundtable Q. 5, 2014-0534851C6 F- 2014 APFF Roundtable, Q. 5- 251.1(3) Definition of "contributor" Income Tax Act- Section 251.1- Subsection 251.1(3)- Contributor contributor includes decedent 10 October 2014 APFF Roundtable Q. 6, 2014-0538251C6 F- 2014 APFF Roundtable, Q. 6- Application of subsection 75(2) after Sommerer General Concepts- Rectification & Rescission no comment on Pallen Trust 10 October 2014 APFF Roundtable Q. 7, 2014-0538281C6 F- 2014 APFF Roundtable, Q. 7- Insured annuity Income Tax Act- Section 138- Subsection 138(12)- Life Insurance Policy whether an annuity is assimilated to a life insurance policy 10 October 2014 APFF Roundtable Q. 9, 2014-0538631C6 F- 2014 APFF Roundtable, Q. 9- Currency conversions average foreign exchange rate Income Tax Act- Section 261- Subsection 261(1)- Relevant Spot Rate use of spot rates for capital property 10 October 2014 APFF Roundtable Q. 10, 2014-0538641C6 F- 2014 APFF Roundtable, Q. 10- Application of 248(35), (36) and (37)(g). Income Tax Act- Section 248- Subsection 248(35) s. 248(35) does not apply where gifted property previously was bequested on s. 70(6) rollover basis Income Tax Act- Section 248- Subsection 248(36) bequest on FMV basis 10 October 2014 APFF Roundtable Q. 15, 2014-0538151C6 F- 2014 APFF Roundtable, Q. 15- Section 143.4 & Reverse Earn-out Income Tax Act- Section 143.4- Subsection 143.4(2) reverse earnout obligation of Buyco re Target shares Income Tax Act- Section 80- Subsection 80(1)- Excluded Obligation reverse earnout obligation of Buyco re Target was excluded obligation ...

[T]he section … [applies] without regard to the extent of the support; in relation to the costs of the accommodation, the support can be modest or it can be the entire cost or anything in between. ... The Queen, 2017 TCC 210 under s. 191.1(1) – government funding. ...

These (and the other full-text translations covering the last 3 ½ years of CRA releases) are subject to the usual (3 working weeks per month) paywall. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2017-11-29 11 October 2017 Internal T.I. 2017-0719181I7 F- Agreement in writing Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (g.4) pre-production mine development expenses that qualify under CEE – (g.4) need not qualify under (g.3) Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (g.3) unresolved ambiguity re whether agreement can refer to a subcontracting agreement 2014-04-23 12 November 2013 External T.I. 2012-0471621E5 F- Moving expenses- eligible relocation Income Tax Act- Section 248- Subsection 248(1)- Eligible Relocation a multiple move may consist of one or more eligible relocations, and if there is one eligible relocation from Residence 1 to 3, the intermediate moving costs can be deductible Income Tax Act- Section 62- Subsection 62(3)- Paragraph 62(3)(a) costs of moving pets by air could qualify Income Tax Act- Section 62- Subsection 62(3)- Paragraph 62(3)(b) moving furniture to ultimate residence could qualify if not ordinarily residing at intermediate residence Income Tax Act- Section 62- Subsection 62(3) reasonable gas expenses but not car tune-up costs can qualify 12 February 2014 Internal T.I. 2013-0508841I7 F- Application of subsection 75(2) Income Tax Act- Section 75- Subsection 75(2) s. 75(2) does not apply to attribute business losses allocated to the trust by an LP 17 December 2013 Internal T.I. 2013-0510111I7 F- Automobile mise à la disposition d'un employé Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(k) administrative office and third-party office in another city could both be workplaces ...

The “Limited program,” under which there is relief only from gross negligence penalties and prosecution, is now expressed to apply “where there is an element of intentional conduct on the part of the taxpayer or a closely related party” – whereas the draft Circular referred more vaguely to “major non-compliance.” ... CRA has added a statement (perhaps to demonstrate flexibility- see Stemijon / Elfe Juvenile) that “If [VDP] relief is denied... relief of arrears interest and any penalties payable may be requested and considered in accordance with the taxpayer relief provisions as described in IC 07-1R1.... ...

Before the implementation of the above transactions, Holdco and Opco adopted a policy of dividending out all of their operating earnings – but deferred paying any of these dividends until the rulings were granted. ... Summaries of 2015 Ruling 2015-0589471R3 under s. 12(1)(g), s. 55(1) – safe income determination time and s. 85(1). ...

These (and the other full-text translations covering the last 3 ¾ years of CRA releases) are subject to the usual (3 working weeks per month) paywall. Bundle Date Translated severed letter Summaries under Summary descriptor 2014-03-19 4 March 2014 External T.I. 2013-0491981E5 F- Soins à un conjoint inapte Income Tax Act- Section 3- Business Source/Reasonable Expectation of Profit personal care amounts received by a committee may be non-taxable 17 February 2014 External T.I. 2014-0517491E5 F- Bien de remplacement- usages multiples Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(b) rental property not a replacement property for mixed use property 3 March 2014 External T.I. 2014-0519071E5 F- Période de détention de 24 mois pour AAPE Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f) 24-month test met where s. 85(2) and (3) reorganization before sale 30 January 2014 External T.I. 2013-0515761E5 F- Dividend received General Concepts- Payment & Receipt book entries merely record and do not establish that a dividend was paid Income Tax Act- Section 82- Subsection 82(1)- Paragraph 82(1)(a) book entries are ancillary and do not establish receipt 2014-03-12 19 February 2014 External T.I. 2013-0500561E5 F- Payment to a subtrust for minor Income Tax Act- 101-110- Section 104- Subsection 104(18) exercise of discretion by family trust in favour of secondary infant trust 23 January 2014 External T.I. 2013-0515721E5 F- Deferred Salary Leave Plan Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(1)(a)(v) full-time employee cannot return on a part-time basis Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(1)(a)(iii) can have a salary deferral period, then leave, then payback period ...