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These are additions to our set of 2,299 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 18 ¾ years of releases of such items by the Directorate. ... Income Tax Act- Section 50- Subsection 50(1)- Paragraph 50(1)(b)- Subparagraph 50(1)(b)(iii) corporation not insolvent if affiliates intend to pay its creditors, and its shares have value if it has non-capital losses Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) sale of Lossco with no assets but non-capital losses for nil consideration to another subsidiary generated a gain under s. 69(1)(b) General Concepts- Fair Market Value- Shares shares of corporation that had ceased business and had no assets but had non-capital losses had a significant value 8 December 2003 Internal T.I. 2003-0042537 F- CIEE & SRAS Also released under document number 2003-00425370. ...

CRA indicated that it would assess all the reporting periods for which it computed any amount of tax owing by the registrant or any refund or rebate owing by it – so that it was only reporting periods where the amount owing on the return as filed equaled the payment made on filing which it would not assess. ... However, if the returns are filed pursuant to a voluntary disclosure request, CRA indicated that a notice of assessment “will be issued once the voluntary disclosure has been accepted and finalized” – even though, to be accepted, the voluntary disclosure application must “include payment of the estimated tax owing.” ...

., where two controlled foreign affiliates (“CFA1” and “CFA2”); of Canco wholly-own LP, which wholly owns “CFA3,” with CFA3 incurring interest expense that is otherwise deductible in computing its FAPI relative to LP – given, inter alia, that LP is not a “taxpayer (as defined in draft s. 18.2(1)) for EIFEL purposes and draft s. 95(2)(f.11)(ii)(A) provides that s. 18.2(2) does not apply for purposes of computing FAPI of a foreign affiliate. ... For example, where an interest-bearing upstream loan by a CFA to wholly-owning Canco is subject to Canadian withholding tax of 25%, this scenario is neutral from an EIFEL perspective since there is IFE (in Canada) and corresponding IFR (in a wholly-owned CFA) – yet, Canco would recognize IFE but no interest and financing revenues (IFR) since the RAIFR of the CFA would be fully offset by a FAT deduction, being the grossed-up deduction for the 25% Canadian withholding tax. ...

These are additions to our set of 2,432 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 19 ¾ years of releases of such items by the Directorate. ... Income Tax Act- Section 15- Subsection 15(1) benefit where permanent life or critical illness policy transferred gratuitously to shareholder as new policyholder Income Tax Act- Section 148- Subsection 148(9)- Adjusted Cost Basis ACB bump on policy distribution to shareholder equal to s. 15 benefit excess over CSV Income Tax Act- Section 52- Subsection 52(1) ACB bump on policy distribution to shareholder equal to s. 15 benefit in excess of ACB otherwise determined – even in absence of s. 52(1) ...

., US Parent, in the US), the BEPS “deductible payments rule” does not apply if a deduction can be offset against an amount that will be included in income in both jurisdictions, so that if the interest expense can be offset against income of Cansub (which is taxed in both jurisdictions), the rule may not apply – but may apply if Cansub is in a loss position. ... Regarding the potential second package, there is a BEPS scoping rule, which denies a deduction in the payer jurisdiction (Canada) only where the parties are in the same control group or are part of a structured arrangement – so that if this loan is not a structured arrangement, the interest deduction may not be disallowed in Canada. ...

These are additions to our set of 3,167 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 24 ½ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2025-04-09 2024 Ruling 2023-0998291R3 F- Multi-wings split-up net asset butterfly 55(3)(b) Income Tax Act- Section 55- Subsection 55(1)- Distribution split-up butterfly between a divorced couple where excess debt is allocated to land rather than building to produce capital gains treatment Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(b) excess debt allocated on s. 85(1) transfer of land and building to the land so as to produce capital gains rather than recapture 17 January 2025 Internal T.I. 2024-1029791I7 F- SSUC- Rémunération de la haute direction / CEWS- Income Tax Act- Section 125.7- Subsection 125.7(1)- Executive Remuneration no adjustments are made to an eligible entity's Statement of Executive Compensation for NEOs filed pursuant to NI 51-102 for CEWS repayment purposes Income Tax Act- Section 125.7- Subsection 125.7(14) repayment based on NI 51-102 statements, without adjustments 2000-10-13 18 September 2000 External T.I. 2000-0026805 F- PAIEMENTS DANS LE CADRE D'UN CONGEDIEMENT Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance payment in lieu of reasonable notice was s. 5 employment income Income Tax Regulations- Regulation 102- Subsection 102(1) reimbursed legal costs of dismissed employee paid by the employer are not subject to withholding if such costs were deductible under s. 8(1)(b) 3 October 2000 Internal T.I. 2000-0039997 F- VENDEAU-CONFERENCE ET CONGRES Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(f)- Subparagraph 8(1)(f)(v) costs of presentations to improve skills of salespeople who generated commissions to the taxpayer were not capital expenditures, cf. cost of attending conference 20 September 2000 External T.I. 2000-0043435 F- Associé quittant société de personnes Income Tax Act- Section 53- Subsection 53(1)- Paragraph 53(1)(e)- Subparagraph 53(1)(e)(i) adjustments to avoid double taxation on a completed withdrawal from a partnership are considered first by the TSO, generally as part of an audit 2000-09-29 14 September 2000 External T.I. 2000-0037085 F- ALLOCATION DE RETRAITE Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance a lump sum amount paid in satisfaction of salary insurance benefits could not be transmuted into a retiring allowance Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) a lump sum paid in satisfaction of an insurer's obligations under a wage loss replacement plan were taxable irrespective of whether paid as a lump sum and via the employer Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) lump sum wage loss payments paid by an insurance company to the employer for on-payment were subject to source deductions 14 September 2000 External T.I. 2000-0023515 F- TAXE DE VENTE AVANTAGE IMPOSABLE Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) payment by employer of sales tax on insurance premiums under an employee-funded sickness or accident insurance plan did not taint the plan Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment by employer of sales tax on insurance premiums under an employee-funded sickness or accident insurance plan is a taxable benefit 2000-09-15 11 September 2000 External T.I. 2000-0045115 F- FERR TRANSFERT Income Tax Act- Section 60- Paragraph 60(l) an individual's spouse may make a transfer from a spousal RRIF a non-spousal RRIF of the spouse (which then becomes a spousal RRIF) Income Tax Act- Section 146.3- Subsection 146.3(5.1) spousal RRIF status has relevance only for purposes of s. 146.3(5.1) ...

These are additions to our set of 3,182 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 24 ½ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2025-04-23 4 January 2022 External T.I. 2016-0644861E5 F- Travail de nature temporaire Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) the "duties … of a temporary nature" condition is tested on a site-by-site basis 28 March 2025 External T.I. 2016-0662951E5 F- Alinéa b) de la définition d’action admissible de Income Tax Act- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (b) settling QSBCS shares on a personal trust with related beneficiaries before a sale of those shares 6 months’ later would not cause QSBCS status to be lost Income Tax Act- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f) settling QSBCS shares on a personal trust whose beneficiaries were related as required by s. 110.6(14)(c)(ii) permitted a sale thereafter without loss of QSBCS status 2000-09-15 29 August 2000 Internal T.I. 2000-0023187 F- Société privée sous contrôle canadien Income Tax Act- Section 125- Subsection 125(7)- Canadian-Controlled Private Corporation ultimate control of Opco was held by Pubco through an indirect wholly-owned subsidiary that was the general partner of an LP holding 2/3 of Opco’s voting shares Income Tax Act- Section 251- Subsection 251(2)- Paragraph 251(2)(b)- Subparagraph 251(2)(b)(i) GP generally controls a corporation whose voting control is held by a limited partnership 16 September 1999 Internal T.I. 9913460 F- CONF. ...

3 August 2016- 12:23am Exercise of employee stock options before a s. 86 spin-off transaction may entail reliance on a comfort letter Email this Content Where, prior to implementation of a spin-out, employees exercise their options to acquire common shares of the pre-spin corporation, which are then exchanged under a s. 86 reorg for new common shares and special shares (to be exchanged under the Plan of Arrangement for Spinco shares), under current law the common shares acquired on exercise would not qualify as prescribed shares (due to their imminent cancellation) – although a November 29, 2012 comfort letter issued to Ian Gamble re the Telus transaction recommends fixing this problem. ...

8 September 2016- 12:20am CRA finds that qualification of partnership units as interests in a family farm or fishing partnership can be based on a previous period of farming use of its assets Email this Content In the situation where a farming couple held a partnership holding the farm property, which leased the farm to a farm corporation, also owned by them, which used the land in its farming business for the first 11 of the 20 years that the land was held by the partnership – but, then, apparently ceased operations, CRA accepted that their interests in the partnership qualified under the s. 110.6 definition of "interests in a family farm or fishing partnership," because the land was used in the farming business for over half of the 20-year holding period by the partnership. ...

10 September 2016- 12:09am CRA’s audit practice is to interpret the central-paymaster provision (Reg. 402.1) restrictively Email this Content The central-paymaster provision in Reg. 402.1 likely is intended to ensure that the general inter-provincial income allocation formula in Reg. 402(3) (which gives ½ weight to the relative payroll borne by the respective provincial permanent establishments) is uanaffectd where the business has one corporation (Payco) bearing payroll for the whole group. ...