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14 March 2013 Internal T.I. 2012-0451131I7- Trustee's Rights & Obligations under the Act-- summary under Subsection 150(3) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(3) Although s. 22 of the Bankruptcy and Insolvency Act requires a trustee to file only the return for the taxation year before the year of bankruptcy, and the return for the year of bankruptcy, s. 164(2.01) of the Act forbids the Minister from paying a refund where returns have not been filed under the Act. ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate-- summary under Subsection 90(6) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(6) inclusion not dependent of maintenance of creditor affiliate status Where a non-resident subsidiary (FA) of Canco has made a loan to a non-resident subsidiary (SisterCo) of Canco’s non-resident parent (Foreign Parent), CRA considers that it is irrelevant that FA has ceased to be a creditor affiliate of SisterCo two years later, as a result of the sale by Canco of FA to Foreign Parent, so that s. 90(6) could still apply to include the loan’s amount in Canco’ income. ...

17 March 1997 Internal T.I. 9631007- INTERACTION OF 85(1) & 110.6(19)-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) The benefit of making an election under s. 110.6(19) in respect of an eligible capital property or a depreciable property effectively will be lost if the property is transferred on a rollover basis to a corporation. ...

14 July 1994 Internal T.I. 9407377- NON-RESIDENT PARTNER & 216 ELECTION (7558-3)-- summary under Regulation 805 Summary Under Tax Topics- Income Tax Regulations- Regulation 805 If a partnership is determined to be carrying on business in Canada, there will be no Part XIII tax liability in respect of rent paid to the partnership on the presumption that a non-resident partner is considered to be carrying on business through a permanent establishment in Canada. ...

17 December 1996 Internal T.I. 9625727- REMARRIAGE CLAUSE & DEF'N OF SPOUSAL TRUST-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) Where a will provided that the widow was entitled to receive the income of the estate but that her entitlement was "to be terminated upon her death or remarriage", and it is proposed that a court order be obtained removing the remarriage clause, RC will accept that the property of the estate vested indefeasibly in the spouse's trust within the 36-month period only if the court order is made within 36 months of the date of death. ...

& Section 116116(5)-- summary under Subsection 49(3) Summary Under Tax Topics- Income Tax Act- Section 49- Subsection 49(3) S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103-- summary under Paragraph 103(4)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) Where a retiring allowance of $30,000 was paid in 30 equal weekly payments of $1,000 to a Quebec employee, the Directorate determined that the rate of withholding would be determined under Reg. 102(1) on the basis of being periodic payments of $1,000 rather than pursuant to Reg. 103(4)(c)(i) as a lump sum payment over $15,000. ...

24 March 2005 Internal T.I. 2005-0115921I7- Specified debt obligations & loan originating cost-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract debt definition- includes conditional sales contracts Conditional sales contracts purchased by a corporation likely would qualify as "debt obligations," so that the corporation would qualify as a restricted financial institution, i.e., a corporation whose principal business was the purchasing of debt obligations issued by arm's length persons. ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit-- summary under Subsection 126(2) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(2) The Directorate agreed that the taxpayer, which was a Canadian maunufacturer 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. ...

4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9)-- summary under Subsection 116(1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(1) personal-use land and building are one property A U.S. resident owned vacant land in Canada from before September 26, 1980 and after that date built a cottage thereon. ...