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8 June 1990 Income Tax Severed Letter ACC9566- Adverse Decision — Federal Court–Trial Division Unedited CRA Tags none Appeals & Referrals Division Technical Publications Division Ms L.C. ...

7 June 1991 Income Tax Severed Letter- Acceptability of a Trust as a Health & Welfare Trust Unedited CRA Tags 6(1)(a), 15(1), 18(1)(a), 248(1) Subject: Draft Health & Welfare Trust This is in reply to your memorandum dated March 27, 1991 wherein you requested our comments as to the acceptability of the trust agreement as a Health & Welfare Trust. The following are our general comments and areas of concerns with respect to the draft Health & Welfare Trust agreement. HEALTH & WELFARE TRUSTS As stated in paragraph 6 of Interpretation Bulletin IT-85R2, to qualify for treatment as a health & welfare trust, (1) the funds of the trust cannot revert to the employer, (2) the employer's contributions to the fund must not exceed the amount required to provide the benefits, (3) the payments by the employer cannot be made on a voluntary or gratuitous basis, and (4) the trustee must act independently of the employer and the payments must be enforceable by the trustee should the employer decide not to make the payments required. ...

13 October 1993 Ruling 9320491- Déductibilité des intérets — Interest Deductibility Unedited CRA Tags 20(1)(c) APFF — CONGRES 1993NOTES AU DOSSIER Question 7 La question de savoir si des actions ordinaires ont été acquises dans le but d'en tirer un revenu est une question de faits et chaque situation doit être examinée en tenant compte des faits particuliers à la situation. ...

3 October 1996 External T.I. 9628565- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES Unedited CRA Tags 146(8) 20(1)(bb) 146.3(11) 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: 1)RRSP & RRIF admin fees; 2)RRSP & RRIF investment management fees Position: 1)Confirming new position that administration fees paid inside RRSP or RRIF trust do not constitute benefit or amount received to annuitant; 2)Confirming old position that investment management fees paid by annuitant are considered payment of a premium to RRSP but not a gift to RRSP for section 146 and Part X.1 purposes; confirming that payment of such RRIF expenses by annuitant is forbidden by 146.3(2)(f) and would cause income inclusion under 146.3(11). ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP Unedited CRA Tags REG 8502(d) 20(1)(bb) 9 146(8) 146.3(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 Department. ... Principal Issues: 1)RRSP & RRIF admin fees; 2)RRSP & RRIF investment management fees; 3)RPP (money purchase) admin fees and investment management fees. ...

3 October 1996 External T.I. 9631795- RRSP ADMINISTRATION & INVESTMENT MANAGEMENT FEES Unedited CRA Tags 146(8) 9 20(1)(bb) 146(5) 146.3(11) 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: 1)RRSP & RRIF admin fees; 2)RRSP & RRIF investment management fees Position: 1)Confirming new position that administration fees paid inside RRSP or RRIF trust do not constitute benefit or amount received to annuitant; 2)Confirming old position that investment management fees paid by annuitant are considered payment of a premium to RRSP but not a gift to RRSP for section 146 and Part X.1 purposes; and that payment of such RRIF expenses by annuitant is forbidden by 146.3(2)(f) and would cause income inclusion under 146.3(11). ...

10 October 1996 External T.I. 9633645- RRSP ADMIN & INVESTMENT FEES Unedited CRA Tags 20(1)(bb) 9 146(8) 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: 1)RRSP & RRIF admin fees; 2)RRSP & RRIF investment management fees Position: 1)Confirming position that administration fees paid inside RRSP or RRIF trust do not constitute benefit or amount received to annuitant; 2)Confirming position that investment management fees paid by annuitant are considered payment of a premium to RRSP but not a gift to RRSP for section 146 and Part X.1 purposes; confirming that payment of such RRIF expenses by annuitant is forbidden by 146.3(2)(f) and would cause income inclusion under 146.3(11). ...

5 December 2017 Roundtable, 2017-0734841C6- 2017 TEI – Question E3 Unedited CRA Tags 87(8.4), (8.5), 116 Principal Issues: Joint election under proposed paragraph 87(8.4)(e) and its interaction with section 116. ... TEI – CRA Liaison Meeting – December 5, 2017 Question E3- Section 116 procedures for tax-deferred dispositions of taxable Canadian property on foreign mergers Background On September 16, 2016, the Department of Finance released draft legislation (proposed subsections 87(8.4) and (8.5)) to provide a mechanism for deferral of recognition of gains and losses from dispositions of shares of Canadian-resident corporations caused by certain foreign mergers, provided such shares are “taxable Canadian property” (“TCP”) and do not constitute “treaty-protected property.” ...

7 December 1993 Income Tax Severed Letter 9333340- PE & Employee-employer Relationship 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. ... DRAFT Tax Executive Institute December 7, 1993 Question No. 8 PERMANENT ESTABLISHMENT ISSUES — CROSS BORDER MANAGEMENT SERVICES With the increase in cross-border activity generally and the increasing integration of the Canadian and U.S. operations in particular, there is also increased sharing of human resources between the parent and subsidiary company. ... V & XV of the U.S. Convention and Art. 5 & 15 of OECD Model-Sections 115(1), 248(1) & 253 ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate Unedited CRA Tags 90(6); 90(8)(a); 90(14) Principal Issues: Whether the exception in 90(8)(a) would apply where the "creditor affiliate" is sold for cash consideration before the 2-year time limit? ... Chantal Tubie HEADQUARTERS Senior Technical Specialist Income Tax Rulings International and Large Business Directorate Directorate International Tax Division Sylvain Grégoire International Advisory Services Section (East) 344 Slater Street, 6th Floor, Minto Place Ottawa ON K1A 0L5 2016-064552 Upstream Loan Rules – Sale of Creditor Affiliate This is in reply to your correspondence of May 2, 2016, wherein you requested our comments as to whether a taxpayer resident in Canada would have an income inclusion pursuant to subsection 90(6) if it transfers the shares of a foreign affiliate to a non-arm’s length purchaser in a case where the foreign affiliate ceases to be a “creditor affiliate”, within the meaning of that subsection, before the expiration of the two year time limit referred to in paragraph 90(8)(a) and the upstream loan remains outstanding after that time limit. ... Facts For illustrative purposes, we will use the following assumed facts: • A non-resident corporation (Foreign Parent) owns all the issued and outstanding shares of a corporation resident in Canada (Canco) and another non-resident corporation (SisterCo). • Canco owns all the issued and outstanding shares of another non-resident corporation (FA). • In 2013, FA makes a loan to SisterCo. • Before the expiration of the two year time limit specified in paragraph 90(8)(a), Canco sells its shares of FA to Foreign Parent for cash consideration. • The loan remains outstanding for more than two years. ...