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The relevant exclusions are: Paragraph (l) – if the non-resident trust is a foreign affiliate of the taxpayer for purposes of section 233.4 of the Act. ... Paragraph (m) – if the interest in the non-resident trust was not acquired for consideration by the taxpayer, or certain other persons. ... Paragraph (n) – if the trust is described in paragraph (a) or (b) of the definition of “exempt trust” in subsection 233.2(1) of the Act. ...

Principal Issues: Deductions available on optional returns under 70(2), 104(23)(d) & 150(4) 1. ... An RRSP deduction, like deductions for an ABIL, exploration & development, moving expenses, can only be claimed on the final return. ... Murphy for Director International and Trusts Division Income Tax Rulings Directorate c.c.: Wendy Coderre Partnerships Information Returns, Capital Gains, Deceased & RCA Specialty Publications Section Client Services Directorate ...

2 November 2015 External T.I. 2015-0594431E5- Ontario Energy & Property Tax Credit Principal Issues: Are land lease payments for a mobile home eligible for determining the Ontario Energy & Property Tax Credit? ... XXXXXXXXXX 2015-059443 George A Robertson, CPA CMA (905) 721-5196 November 2, 2015 Dear XXXXXXXXXX, This is in response to your letter dated June 2, 2015, enquiring whether the land lease cost paid by you can be used in the property tax amount of the calculation of the Ontario Energy & Property Tax Credit (“OEPTC”). ...

3 March 2023 External T.I. 2022-0959251E5- Microprocessor knee prosthesis & the METC Unedited CRA Tags 118.2(2)(i) of the Act and 5700(i) of the Regulations Principal Issues: Whether the cost of a microprocessor knee prosthesis (or C-Leg) would be an eligible expense for the purpose of the medical expense tax credit. ... Reasons: The wording in paragraph 118.2(2)(i) which provides for amounts paid “for, or in respect of, an artificial limb […].” ... Information on how to claim the METC is available on the webpage titled “Lines 33099 and 33199 – Eligible medical expenses you can claim on your tax return.” ...

16 November 2015 External T.I. 2015-0595041E5- Mutual Fund Trusts & 108(2)(a)(i) CRA Tags 108(2)(a) 132(6) Principal Issues: Does CRA still consider a redemption schedule more than once annually satisfying 108(2)(a)(i)? ... Yours truly, Phil Kohnen Manager, Trusts Section I Financial Industries and Trusts Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

26 May 1995 External T.I. 9513715- CREDITOR LIFE INSURANCE & CDA Unedited CRA Tags 89(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Yours truly, Director Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

20 January 2000 External T.I. 9932435- DEDUCTIONS FROM OAS & CPP BENEFITS Unedited CRA Tags 8 5(2) 3(d) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: Whether employment expenses can be deducted from OAS & CPP benefits. ...

18 October 1999 External T.I. 9919265- STOCK OPTIONS & CCPC Unedited CRA Tags 7(1.1) 110(1)(d.1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: Whether CCPC options or shares are still eligible for 7(1.1) & 110(1)(d) or (d.1) treatment Position: Yes Reasons: Wording of 7(1.4) and 7(1.5) XXXXXXXXXX 991926 S. ...

12 October 1995 External T.I. 9512485- PARTITION OF ACCOUNTS RECEIVABLES & OTHER FUNGIBLES. ... Principal Issues: APPLICATION OF 248(20) & 248(21) WHERE THE SUBJECT PROPERTY IS ACCOUNTS RECEIVABLES INVENTORY AND OTHER LIKE PROPERTY COMPRISED OF NUMEROUS INDIVIDUAL PROPERTIES? ...

14 November 2002 External T.I. 2002-0136625- Compound interest & thin capitalization Unedited CRA Tags 18(5) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Yours truly, Olli Laurikainen for Director International & Trusts Division Income Tax Rulings Directorate ...