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2 May 1995 T.I. 951062 (File &- 951174 (C.T.O. "New Trust Seed Money from Financial Institution")-- summary under Financial Institution Summary Under Tax Topics- Income Tax Act- Section 142.2- Subsection 142.2(1)- Financial Institution A new trust that is established with "seed money" contributed by a manager or sponsor that is a financial institution will itself be a financial institution until the time that investors purchase units in the trust, thereby reducing the interest of the manager or sponsor below the 50% threshold. ...

2013 Ruling 2013-0488661R3- Indian Band-Public Body & Function of Government-- summary under Paragraph 149(1)(c) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(c) Indian band An Indian Band governed by an elected chief and band council, which provides a wide range of listed health, social, educational and economic services to its members, is ruled to be a public body performing a function of government in Canada within the meaning of s. 149(1)(c). ...

14 March 2013 Internal T.I. 2012-0451131I7- Trustee's Rights & Obligations under the Act-- summary under Paragraph 241(4)(k) Summary Under Tax Topics- Income Tax Act- Section 241- Subsection 241(4)- Paragraph 241(4)(k) The Minister may disclose information respecting the bankrupt to the trustee in bankruptcy without a T103 given that the trustee is deemed to be the bankrupt's agent by s. 128, and the trusteee is entitled to taxpayer information under s. 164(1) of the Bankruptcy and Insolvency Act. ...

8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10-- summary under Subsection 207.6(2) Summary Under Tax Topics- Excise Tax Act- Section 207.6- Subsection 207.6(2) In response to a question as to whether CRA has considered whether subsection 207.6(2) could apply to segregated fund policies and if yes, in what circumstances, CRA stated: [S]ince the definition "life insurance policy" in subsections 138(12) and 248(1) of the Act includes a segregated fund policy, we agree that such policies fall within the scope of the rule. ...

8 November 1996 Internal T.I. 9635527- INTERACTION SECTION 216 & SECTION 188.94-- summary under Section 118.94 Summary Under Tax Topics- Income Tax Act- Section 118.94 Even though Part XIII tax is levied on the gross amount of a particular payment, for the purpose of calculating a non-resident's world income such amount is reduced by applicable expenses. ...

8 November 1996 Internal T.I. 9635527- INTERACTION SECTION 216 & SECTION 188.94-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) "The filing of a return of income pursuant to section 216 cannot have any impact on whether or not an individual meets the 'all or substantially all' test in section 118.94. ...

24 March 1994 External T.I. 9335755- RRIF PAID TO UK RESIDENT- PENSION & ANNUITY (U4-100-17)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Notwithstanding the definition for "annuity" found in s. 5 of the Income Tax Conventions Interpretation Act, a payment out of a RRIF which qualifies as a "periodic pension payment" under the ITCIA which is paid to a resident of the UK, falls under the term "pension" in paragraph 3 of Article XVII of the UK Convention. ...

28 April 1994 Internal T.I. 9331017- TERMINAL LOSSES & LOSS OF TAX EXEMPT STATUS-- summary under Subsection 149(10) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(10) A terminal loss in the year of change from exempt to taxable status is deductible. ...

6 June 1994 External T.I. 9337485- Partie XIII — Droit d'utilisation de logiciels information-- summary under Subparagraph 212(1)(d)(i) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(i) The position of Revenue Canada that a payment for the use of, or the right to use, software in Canada is caught by s. 212(1)(d)(vi) applies even if the payment is made as a lump sum rather than periodically. ...

30 September 1994 Internal T.I. 9414527- BORROWINGS & EXCESS INSURANCE COLLATERAL-- summary under Paragraph 20(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.2) Where the life insurance coverage under an assigned policy is $500,000 and the average balance owing under the borrowing is $200,000, the amount deductible under s. 20(1)(e.2) is limited to 40% of the lesser of the premiums payable and the net cost of pure insurance under the policy for the year. ...