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These are additions to our set of 3,030 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 23 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 3,083 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 23 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2025-02-12 11 December 2024 External T.I. 2024-1039101E5 F- Vertical amalgamation & former paragraph 84.1(2)(e) Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) s. 87(2)(j.6) continuity rule does not remediate the adverse consequences under the old intergenerational transfer rules of vertically amalgamating the subject corp Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(j.6) s. 87(2)(j.6) does not apply for purposes of the “old” s. 84.1(2)(e) intergenerational transfer rules 2001-02-02 23 October 2000 Internal T.I. 2000-0027477 F- ALLOCATION DE RETRAITE Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance exclusion for replacement employment at an alleged affiliated employer was not applied 2001-01-19 5 January 2001 External T.I. 2000-0010905 F- Valuation- Freeze shares General Concepts- Fair Market Value- Shares requirement to seek consent detracts to retraction detracts from FMV of freeze preferred shares Income Tax Act- Section 86- Subsection 86(1) right to retract freeze preferred shares must not be fettered 4 January 2001 External T.I. 2000-0047605 F- FRAIS DE DIVERTISSEMENT Income Tax Act- Section 67.1- Subsection 67.1(1) attending shows in order to identity artist recruits might be entertainment Income Tax Act- Section 67.1- Subsection 67.1(2)- Paragraph 67.1(2)(a) s. 67.1(2)(a) exception unavailable for tickets to shows attended to recruit artists 10 January 2001 External T.I. 2000-0049585 F- DEDUCTIBILITE DES INTERETS Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) annual payment cap on interest until maturity did not preclude deductibility 5 January 2001 Internal T.I. 2000-0053767 F- IT-92R2 Paragraphe 1 Income Tax Act- Section 9- Timing progress method per IT-92R2 could be used by supplier of kitchen equipment if installed by it pursuant to the building construction plans and title thereto thereupon vested in the building owner Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(b) construction holdbacks not receivable until approved for release 2001-01-05 19 December 2000 External T.I. 2000-0035685 F- RPA TRANSFER AU DECES Income Tax Act- Section 147.3- Subsection 147.3(7) deceased member can have had more than one qualifying spouse or partner ...

These are additions to our set of 3,129 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 ¼ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2000-11-24 3 November 2000 External T.I. 2000-0047535 F- CHNT USAGE-UN IMMEUBLE Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(a) building of the taxpayer with 4 units treated as 4 separate properties for purposes of the change-in-use rules Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(b)- Subparagraph 13(7)(b)(ii)- Clause 13(7)(b)(ii)(B) change in use of unit in 4-plex from personal to rental and vice versa 31 October 2000 Internal T.I. 2000-0048427 F- PENSION ALIMENTAIRE-ARRERAGES Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount amount of support can be payable under a court order although the amount paid is less 10 November 2000 External T.I. 1999-0008335 F- inclusion revenu exonéré- convention fiscale Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(a) requirement to include a treaty-exempt receipt in income 9 November 2000 External T.I. 2000-0038955 F- CLAUSE DE CAPACITE DE GAIN Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) ascertaining 5-year earnout period / meaning of “calculated with certainty” 7 November 2000 External T.I. 2000-0040615 F- OPTIONS ET CLAUSE DE CAPACITE DE GAIN Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) IT-426 cost-recovery method not available where earnout is embedded in the variable proceeds received for the granting of a share-sale option with nominal exercise price Income Tax Act- Section 49- Subsection 49(1) granting of earnout option may require full recognition under s. 49(1) on grant date/ legal form of option v. share sale generally followed 7 November 2000 External T.I. 2000-0041815 F- ALLOC. ...

These are additions to our set of 3,174 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 Translated severed letter Summaries under Summary descriptor 2016-11-16 24 June 2016 External T.I. 2015-0571471E5 F- Passe de ski familiale Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) no taxable benefit if all employees given season’s pass at ski resort/gift policy also applicable 2 August 2016 External T.I. 2014-0544941E5 F- Interaction between ss. 111(12) and 80.01(3) Income Tax Act- Section 80.01- Subsection 80.01(3) deemed settlement under 80.01(3) before operation of 111(12) Income Tax Act- Section 111- Subsection 111(12) no accrued FX loss on a loan owing by a target to a sub is realized on an AOC where there is a same-day amalgamation and no time-stamping 2016-10-19 22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) inter-affiliate loan generating deemed active business funded out of an interest-free loan from Canco Income Tax Act- Section 248- Subsection 248(5) ordinary meaning of “substituted” Income Tax Act- Section 93- Subsection 93(2.01) a contribution of FA1 shares to FA2 causes the FA2 shares to be substituted property for s. 93(2.01) purposes 2016-01-20 3 December 2015 External T.I. 2015-0593941E5 F- Allocation of the safe income on hand General Concepts- Fair Market Value- Shares FMV of discretionary share increased at moment of dividend declaration to exclusion of other discretionary shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) flexible allocation of SIOH where discretionary common shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) quaere whether 8% reduction is significant 26 March 2015 Internal T.I. 2013-0503031I7 F- Existence d’une source de revenu Income Tax Act- Section 3- Business Source/Reasonable Expectation of Profit individual’s sideline activity not a business so that revenues exempt Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose criteria for determining whether a home is a principal place of business 8 December 2015 External T.I. 2015-0616321E5 F- CEE- Severance pay Income Tax Regulations- Regulation 1206- Subsection 1206(1)- Canadian exploration and development overhead expense exclusion of severance payment Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (a) severance payment not includible in CEE 8 June 2015 External T.I. 2014-0529851E5 F- Frais payés à une maison de santé ou de repos Income Tax Act- Section 118.2- Subsection 118.2(1) expenses can be claimed based on 12-month period ending in year Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(d) floor of retirement residence servicing those with advanced Alzheimer’s can qualify as “nursing home” Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(e) no 2nd credit under s. 118.3 re accommodation expenses in nursing home 11 December 2015 External T.I. 2015-0601561E5 F- Attribution Rules Income Tax Act- Section 74.4- Subsection 74.4(2) annual dividends by an SBC to a non-SBC are not an indirect transfer of property to the non-SBC by the individual who formed the SBC ...

T.I. 2012-0463801E5 F- Déduction pour gain en capital – permis de pêche Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(b) para. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2017-03-15 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.1, 2016-0674221C6 F- General deduction from tax- 123.4 Income Tax Act- Section 123.4- Subsection 123.4(1)- Full Rate Taxable Income income on which the SBD was not claimed nonetheless is not eligible for the general rate deduction 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.2, 2017-0682711C6 F- Dedicated Telephone Service for Income Tax Service Income Tax Act- Section 152- Subsection 152(1) telephone service for those with complex technical tax issues will initially be limited to Ontario and Quebec CPAs 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.3, 2016-0674821C6 F- Individuals separated living under the same roof Income Tax Act- Section 122.6- Cohabiting Spouse or Common-Law Partner couple under the same roof can be living separate and apart Income Tax Act- Section 248- Subsection 248(1)- Common-Law Partner meaning of living "separate and apart" 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.4, 2016-0674831C6 F- Changement d'usage- duplex Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(c) substantially renovating the personal-use portion of a rental property (without changing floor areas) generally would not engage the change-of-use rules Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) apportionment of operating expenses of duplex used both personally and for rental income Income Tax Act- Section 248- Subsection 248(1)- Property duplex is single property 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.5, 2016-0674801C6 F- Allocation et frais d'une automobile Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(k)- Subparagraph 6(1)(k)(v) electric vehicles treated the same Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) general reasonability of a car allowance rate of $0.54/$0.48 per kilometre including for electric vehicles 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.6, 2016-0674861C6 F- Wholly dependent person tax credit Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b)- Subparagraph 118(1)(b)(ii) meaning of support/legal custody not required/ITA is silent on number of days child must spend with parent 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.7, 2016-0674811C6 F- Allocations automobiles & dépenses afférentes Income Tax Regulations- Regulation 200- Subsection 200(3) correction of T4s Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) if vehicle allowance is too low, employee can include the allowance and deduct the vehicle expenses/T2200 production expected 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.8, 2016-0674851C6 F- HBTC- Acquisition by way of gift Income Tax Act- Section 118.05- Subsection 118.05(1)- Qualifying Home gifted home can qualify for the HBTC ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2018-04-25 12 June 2017 Internal T.I. 2016-0679291I7 F- Régime d’assurance décès et mutilation accidentels Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(e.1) the payment of group accident plan premiums by an employer for its benefit gave rise to taxable benefits 2018-04-11 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 1, 2017-0705221C6 F- Property transfers- common law partners in Québec Income Tax Act- Section 146- Subsection 146(16)- Paragraph 146(16)(b) a common-law partners’ separation agreement can engage s. 146(16)(b) or 146.3(14) rollover even if technically they have no legal rights to settle Income Tax Act- Section 73- Subsection 73(1.01)- Paragraph 73(1.01)(b) rollover under common-law partners' separation agreement irrespective of whether technically they have separation rights to settle Income Tax Act- Section 146.3- Subsection 146.3(14) rollover pursuant to common-law partners' settlement agreement 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2017-0710681C6 F- Withdrawal of RRSP over-contributions after death Income Tax Act- Section 146- Subsection 146(8.8) income inclusion under s. 146(8.8) on death irrespective whether premiums exceeded deductible amount Income Tax Act- Section 146- Subsection 146(8.2) deemed s. 146(8.8) benefit on death treated as RRSP withdrawal, and executor should not use Form T746 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 4, 2017-0707781C6 F- Withdrawal of undeducted RRSP contributions Income Tax Act- Section 146- Subsection 146(8.2) s. 146(8.2) deduction for withdrawing excess contributions can be available even where Pt X.1 tax is not applicable 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 5, 2017-0707801C6 F- RRIF transfers – partition of family patrimony Income Tax Act- Section 146.3- Subsection 146.3(14) amount paid to surviving spouse's RRIF did not qualify under s. 146.3(14) Income Tax Act- Section 146.3- Subsection 146.3(1)- Designated Benefit payment from a deceased’s RRIF to the RRIF of the surviving spouse who was excluded under the will qualified as designated benefit Income Tax Act- Section 60- Paragraph 60(l) transfer from deceased's RRIF to RRIF of surviving spouse in settlement of claim 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 6, 2017-0707791C6 F- RRIF- Successive Deaths Income Tax Act- Section 146.3- Subsection 146.3(1)- Designated Benefit death of the surviving spouse before she received payment of the testator’s legacy of his RRIF precluded access to the designated benefit rules Income Tax Act- Section 146.3- Subsection 146.3(6.1) s. 146.3(6.1) did not apply as the executor did not receive the RRIF legacy ...