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In Example 3, per “ Geransky and Kennedy, the sale of the capital assets in and of itself should not constitute a reorganization for the purposes of subsection 84(2) provided that R Co continues to carry on the same business.” ...

These are additions to our set of 1,977 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 16 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2005-04-01 23 March 2005 Internal T.I. 2005-0113931I7 F- Safe income on hand calculation: Life Insurance Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) non-deductible life insurance premiums reduced SIOH 2005-03-25 22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit Income Tax Act- Section 207.7- Subsection 207.7(2) where LC used to secure RCA benefits and refundable tax generated on funding of LC fees, refundable tax not recoverable based on paying the benefits Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax use of letter of credit to secure RCA benefits Income Tax Act- Section 207.5- Subsection 207.5(2) election not available to custodian holding an LC 22 March 2005 Internal T.I. 2005-0115451I7 F- Extinction d'une remise de dette Income Tax Act- Section 80- Subsection 80(1)- Forgiven Amount no deduction where forgiven debt is subsequently restored pursuant to improved fortunes clause Income Tax Act- Section 80.01- Subsection 80.01(10) repayment deduction under s. 80.01(10) General Concepts- Effective Date CRA assesses based on the state of affairs at year end 2005-03-18 1 February 2005 External T.I. 2004-0083921E5 F- Société mandataire, gain & CIÉ Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax US taxes paid by a corporation based on falsely representing that the related gain was its gain could generate a FTC to the Canadian shareholder for which it in fact was agent 4 February 2005 External T.I. 2004-0085361E5 F- Changement de résidence: émigration Income Tax Act- Section 122.6- Eligible Individual- Paragraph (c) required repayment of CCB if received after departure from Canada 31 January 2005 External T.I. 2004-0091301E5 F- Déductions à la source-avantage autre qu'en argent Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no source deductions required where a non-cash benefit is the sole remuneration Income Tax Act- Section 153- Subsection 153(1.1) no source deductions required where free accommodation was the intern's only benefit 4 February 2005 External T.I. 2004-0093611E5 F- Don par testament d'un bien culturel Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(a)- Subparagraph 39(1)(a)(i.1)- Clause 39(1)(a)(i.1)(B) s. 39(1)(a)(i.1) unavailable where capital gain realized under s. 104(4)follow-up in 2005-0131741E5 F 15 March 2005 Internal T.I. 2004-0108721I7 F- Don d'une licence Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts gift of a non-exclusive software licence was a gift of property Income Tax Act- Section 248- Subsection 248(1)- Property excepting WIP, definition of property is no broader than term’s ordinary meaning ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2022-04-06 2017 Ruling 2017-0696791R3 F- Reduction of PUC/capital Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by Subco for distribution of share-capital account to its parent is deductible if the Subco property continues generating business incomeAmended and supplemented by 2017-0696792R3 F Income Tax Act- Section 51- Subsection 51(1) s. 51(1) will apply where convertible note, that was issued as boot, will be converted to sharesAmended and supplemented by 2017-0696792R3 F 2019 Ruling 2017-0696792R3 F- Internal reorganization Amending and supplementing 2017-0696791R3 F 7 January 2022 External T.I. 2020-0866751E5 F- CEWS and government financial assistance Income Tax Act- Section 125.7- Subsection 125.7(4) government assistance based partly on payroll levels would not be qualifying revenue if normal accounting practice would be to contra payroll expense Income Tax Act- Section 125.7- Subsection 125.7(1)- Qualifying Revenue government assistance that under normal accounting practice was applied to reduce recorded expenses would not be qualifiying revenue 2005-03-11 3 March 2005 External T.I. 2004-0096371E5 F- Revenu tiré d'un emploi et 110(1)f)(iii) Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(f)- Subparagraph 110(1)(f)(iii) no special tests under s. 110(1)(f)(iii) for determining whether the individual is self-employed 2005-03-04 7 February 2005 External T.I. 2004-0101421E5 F- Subsection 111(5.1) General Concepts- Fair Market Value- Other depreciable assets’ value inferred from the share purchase price Income Tax Act- Section 111- Subsection 111(5.1) FMV of assets should be established on a push-down basis from the share purchase price, but can be allocated based on an appraisal 28 February 2005 Internal T.I. 2004-0103991I7 F- Remboursement de frais de scolarité Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) agreement of employer to pay tuition would have been taxable under s. 6(3) if a benefit Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment of tuition fees conditional on a return to extended employment was not a taxable benefit 28 February 2005 External T.I. 2004-0104121E5 F- Détermination du statut de résidence Income Tax Regulations- Regulation 2607 individual working in Ontario but visiting Quebec family home twice monthly likely was resident in Quebec 7 February 2005 External T.I. 2005-0111431E5 F- Death of a Taxpayer- Deduction of CCDE Income Tax Act- Section 66.2- Subsection 66.2(2) CCDE balance cannot be deducted in terminal return or by estate Income Tax Act- Section 70- Subsection 70(5.2) no s. 70(5.2) deduction where CCDE balance arose “through” a partnership 23 February 2005 External T.I. 2004-0093921E5 F- Déménagement d'un employé-Paiement de frais Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment of house-hunting fee for new hire was non-taxable 2005-02-25 17 February 2005 External T.I. 2004-0091811E5 F- Exemption pour résidence principale Income Tax Act- Section 54- Principal Residence separate municipal addresses not determinative that basement occupied by son and ground floor occupied by mother were two housing units Income Tax Act- Section 54- Principal Residence- Paragraph (a) where residence held by son and mother in equal co-ownership is 2 units each occupied separately, each could technically access the exemption for only a ¼ interest 17 February 2005 External T.I. 2004-0104331E5 F- Indemnisation et autres paiements Income Tax Act- Section 5- Subsection 5(1) portions of settlement payment that compensated for lost vacation credits and reimbursed for psychotherapy and medication costs were taxable under s. 5(1) ...

XXIV de la Convention Canada-France Treaties- Income Tax Conventions- Article 25 Art. 24(1) of Canada-France Convention would provide the principal residence exemption to a Canadian citizen if France accorded the exemption to a French national residing in Canada 6 January 2005 External T.I. 2004-0088791E5 F- Paragraphe 4803(2) du Règlement Income Tax Regulations- Regulation 4803- Subsection 4803(2) Reg. 4803(2) satisfied if any of its paragraphs is satisfied 2005-01-21 19 January 2005 External T.I. 2004-0091601E5 F- Incitatif versé- taux d'intérêt réduit Income Tax Act- Section 53- Subsection 53(2.1) ss. 13(7.4) and 53(2.1) elections unavailable re acquired rental property for cashback received from mortgage lender to offset high interest rate Income Tax Act- Section 12- Subsection 12(2.2) s. 12(2.2) election available to reduce mortgage interest, re cashback received from mortgage lender, to reduce extra interest incurred in two initial years Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(v) s. 12(1)(x) applies (subject to s. 12(2.2) election) to lump-sum mortgage interest rebate except to the extent the amount was reported as s. 9 income 11 January 2005 External T.I. 2004-0091981E5 F- Revenu de placements:Indiens inscrits Other Legislation/Constitution- Federal- Indian Act- Section 87 interest income of status Indians on loans to on-reserve businesses carrying on their business activities off-reserve were not exempted 10 January 2005 Internal T.I. 2004-0091251I7 F- Définition d'automobile Income Tax Act- Section 248- Subsection 248(1)- Automobile- Paragraph (e)- Subparagraph (e)(iii) exclusion applies even where the occupant is self-employed rather than an employee of the business that owns (or leases) the truck 2005-01-14 13 January 2005 External T.I. 2004-0097911E5 F- Crédit d'impôt pour études Income Tax Act- Section 118.6- Subsection 118.6(1)- Qualifying Educational Program education credit unavailable where the course consisted of discrete 4-day sessions separated by a month or more – but tuition credit may be available 13 January 2005 External T.I. 2004-0101701E5 F- Bien substitué Income Tax Act- Section 248- Subsection 248(5)- Paragraph 248(5)(b) substituted property definition in s. 248(5)(b) does not apply for the purposes of s. 7(1.1) Statutory Interpretation- Interpretation/Definition Provisions deeming provision only engaged when the referenced term is used Income Tax Act- Section 7- Subsection 7(1.1) s. 248(5)(b) inapplicable to s. 7(1.1) 13 January 2005 External T.I. 2004-0103281E5 F- dons et avantages Income Tax Act- Section 248- Subsection 248(32) value of advantage should be based on FMV and ignore sales tax and tips ...

., the requirement that all or substantially all of the interest and financing expenses of an entity be paid to persons other than tax-indifferent investors, and is exploring some ways that they could be potentially relaxed without compromising the integrity of the rules – and is also interested in exploring whether most of the requests for specific carve-outs, for sectors or types of businesses, could be appropriately dealt with, through an expansion of the excluded entity definition, and of the availability of the group ratio rule. ...

These are additions to our set of 2,089 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 17 ½ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2004-10-29 8 October 2004 Internal T.I. 2004-0093371I7 F- Crédit d'impôt à l'investissement & impôt minimum Income Tax Act- Section 127- Subsection 127(5)- Paragraph 127(5)(a)- Subparagraph 127(5)(a)(ii) carryback of ITCs from year where the taxpayer was subject to minimum tax 19 October 2004 Internal T.I. 2004-0094971I7 F- Programme de formation admissible Income Tax Act- Section 118.6- Subsection 118.6(1)- Qualifying Educational Program “period” referred to the times at which the individual was receiving income from employment 28 September 2004 Internal T.I. 2004-0079801I7 F- Pension alimentaire Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount settlement of support arrears are not deductible or includible 30 September 2004 Internal T.I. 2004-0083301I7 F- Entreprises distinctes Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) 2 different centres were branches of the same business 30 September 2004 Internal T.I. 2004-0085051I7 F- Intérêts et indemnité additionnelle Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) indemnity under CCQ Art. 1619 was pre-judgment interest Income Tax Act- Section 129- Subsection 129(4)- Income or Loss interest on damages relating to lost business was active business income 19 October 2004 Internal T.I. 2004-0085711I7 F- Dommages suite à une entente hors cour Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance amount received in settlement of grievances and on agreeing to retire was a retiring allowance in the absence of evidence that it was for harassment or unpaid wages Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(n) required repayment of excess amount of wage loss insurance previously received could give rise to s. 8(1)(n) deduction 20 October 2004 Internal T.I. 2004-0086501I7 F- Droits compensateurs Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(vv) posting of bonds for US countervailing duties did not constitute their being “paid” for s. 20(1)(vv) purposes Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) obligation to repay suppliers for extra US countervailing duties charge made to them was contingent until a board decision reversed such duties 8 October 2004 APFF Roundtable Q. 11, 2004-0090791C6 F- Maladies graves et soins de longue durée Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sickness plan can comprise individual critical illness policies Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) periodic payments under long-term care insurance are not taxable Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose premiums for critical illness policies and individual long-term care policies for senior employees are deductible ...

These are additions to our set of 2,125 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 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,134 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 17 ¾ years of releases of such items by the Directorate. ...