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Bundle Date Translated severed letter Summaries under Summary descriptor 2017-06-07 15 May 2017 External T.I. 2015-0580461E5 F- Life insurance policy held in an RCA trust Income Tax Act- Section 207.5- Subsection 207.5(1)- RCA Strip holding of life insurance policy could entail RCA strip Income Tax Act- Section 207.5- Subsection 207.5(3) s. 207.7(2) refund might be generated where an RCA trust distributes a life insurance policy to its employee beneficiary 21 November 2016 Internal T.I. 2016-0641961I7 F- DSU Plan Income Tax Regulations- Regulation 6801- Paragraph 6801(d)- Subparagraph 6801(1)(d)(i) potential change-of-control redemption trigger (and Code s. 409A triggers) were offside Income Tax Act- Section 6- Subsection 6(11) recognition in income of full value of deferred units issued under offside plan 2015-01-28 13 November 2014 External T.I. 2014-0523581E5 F- Prestations de RPA- Exonération Other Legislation/Constitution- Federal- Indian Act- Section 87 taxable portion of RPP benefits of reserve Indian determined based on portion of contributions paid out of taxable earnings 13 November 2014 External T.I. 2014-0535041E5 F- Bien de remplacement – Location d'immeubles Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(a.1) rental property use before and after satisfies test 2015-01-21 3 September 2014 Internal T.I. 2014-0533361I7 F- Ligne directrice 4 Other Legislation/Constitution- Federal- Indian Act- Section 87 Guideline 4 not met where Indian organization had non-Indian clients 5 June 2014 Internal T.I. 2014-0532281I7 F- Chambre des communes-donataire reconnu 149.1(1) Income Tax Act- Section 149.1- Subsection 149.1(1)- Qualified Donee- Paragraph (a)- Sujbparagraph (a)(iii) Parliament does not perform a function of government ...

Summary of 2013 Ruling 2012-0459781R3 under s. 55(1) – distribution. ...

There is a gap in the wording of s. 248(36)- it refers only to the cost or adjusted cost base of property – and not to the adjusted cost basis of a life insurance policy. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2014-07-02 3 June 2014 External T.I. 2013-0503511E5 F- Discretionary Dividend Shares Income Tax Act- 101-110- Section 110.6- Subsection 110.6(7) discretionary dividend prefs used to extract excess cash 14 April 2014 Internal T.I. 2013-0516151I7 F- Article XIII(4) of the Canada-XXXXXXXXXX Convention Treaties- Articles of Treaties- Article 13 partnerships holding Quebec real estate were transparent 2014-06-25 23 May 2014 External T.I. 2014-0518921E5 F- Calcul de l'élément A du MCIA Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital A.1 of A reduction does not apply in year of sale 27 May 2014 Internal T.I. 2014-0521631I7 F- Déductibilité d'un alcoomètre Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose not necessary to show that expenditure generated income- and potential deduction where 20% personal use Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) full personal element if the expense would have otherwise been paid by the employee 3 June 2014 External T.I. 2014-0518911E5 F- Grand routier / long-haul truck Income Tax Act- Section 67.1- Subsection 67.1(5)- Long-haul truck weight reference is to loaded weight determined by manufacturer 2014-06-18 29 May 2014 External T.I. 2014-0520851E5 F- Deferred Salary Leave Plan Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(i) terms cannot provide for voluntary withdrawal of employee except where hardship Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(iv)- Clause 6801(a)(iv)(B) no requirement for employer to provide a return on the deferred amounts ...

Summary of Circular of H&R REIT and H&R Finance Trust under Other – Releveragings. ...

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. ...

Summaries of Angelo Discepola and Robert Nearing, "A Reply to the CRA's Classification of Florida and Delaware LLLPs and LLPs as Corporations," 2016 Conference Report (Canadian Tax Foundation), 24:1-39 under s. 96 and s. 248(1) – corporation. ...

20 February 2018- 11:54pm Five full-text translations of 2013 APFF Roundtable items and Technical Interpretations are available Email this Content The table below provides descriptors and links for two items from the October 2013 APFF Roundtable, as fully translated by us – as well as for three technical interpretations released in January 2014. ...

Tremblay case, Bédard J found that house-repair invoices, that did not give the house address or describe the precise nature of the work performed (and that were rendered in the name of entities that did not remit the GST), failed to satisfy the requirements of s. 3 of the Input Tax Credit Information (GST/HST) Regulations, so that the appellant’s related input tax credit claims were properly denied – and also found that “the appellant did not truly acquire the supplies for which it claimed ITCs.” ...

Summary of 29 May 2018 STEP Roundtable, Q.5 under s. 120.4(1) – excluded share. ...