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4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate-- summary under Subsection 90(14) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(14) deduction not dependent on FA being creditor affiliate at repayment time In 2013, FA, which is wholly-owned by Canco, makes a loan to SisterCo., which is wholly-owned by the non-resident parent of Canco (“Foreign Parent”). ...

3 March 2017 Internal T.I. 2016-0673661I7- Upstream loans – allocation of repayments-- summary under Paragraph 90(8)(a) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(8)- Paragraph 90(8)(a) ordering of upstream loan repayments determined on FIFO basis Prior to August 19, 2011, Canco borrowed $50M (“Advance A”) from its wholly-owned non-resident subsidiary (“FA”), and borrowed a further $50M (“Advance B”) from FA under the same revolving credit facility in October 2012. ...

2 May 2005 Internal T.I. 2005-0119971I7 F- CDA- Excessive Election & Late Filed Election-- summary under Subsection 83(3.1) Summary Under Tax Topics- Income Tax Act- Section 83- Subsection 83(3.1) where no s. 83(2) election filed for statute-barred year, CRA should request late election under s. 83(3.1) or, failing which, assess a taxable dividend under s. 184(4)(b)(ii) CRA never received a s. 83(2) election in respect of a dividend payable in 1997 by Yco to its sole shareholder, an individual ("Y"). ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Clause 95(2)(b)(i)(A) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(b)- Subparagraph 95(2)(b)(i)- Clause 95(2)(b)(i)(A) provision of services for fee by CFA to Canco on arm’s length terms did not oust s. 95(2)(b)(i)(A) Four U.S. ...

27 March 2018 Internal T.I. 2017-0691941I7 F- Investissement frauduleux – Fraudulent Investment-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date court order ab initio declaring loan void would eliminate interest income Individuals had “invested” in what turned out to be a Ponzi scheme under which for many years they reported annual income inclusions for interest which they were treated as having reinvested in the scheme. ...

7 June 2021 Internal T.I. 2020-0873601I7- CERS – restricted activities of a travel agency-- summary under Public Health Restriction Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Public Health Restriction a COVID lockdown closing a travel agency office qualified as a “public health restriction” even if the personnel continued bookings from home Would a travel agency that was required to close its office due to COVID lockdown measures, so that its employees started working from home, qualify for lockdown support under B of s. 125.7(2.1) and the definition of “rent top-up percentage”? ...

22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) ordinarily not applied where a shareholder owes money to a corporation under a genuine or bona fide loan arrangement Discussion of whether s. 15(1) or 56(2) might apply to loans by corporations wholly owned by an individual to a corporation that was partly owned by other persons. ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) place of contract not primary determinant The Directorate agreed that the taxpayer, which was a Canadian manufacturer transferring some of its goods to a Japanese branch for sale there, was overstating its profits for purposes of s. 126(2), by treating most or all of the profits on the sale of such products as being profits of the Japanese branch. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) no pro-ration of FTC by s. 94 trust where Canadian gain was smaller than US gain A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Paragraph 94(3)(b) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(3)- Paragraph 94(3)(b) A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...