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21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election CRA Tags ITR 5901(2.2) S.79 of Bill C-48 ITR 5901(2.1) ITR 5901(2)(b) 95(1) foreign accrual property income Principal Issues: 1) Do the surplus pools of a given CFA have to be adjusted as a result of a FACL carryback against the TCG portion of the FAPI inclusion reported in a previous year? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2014-056081 FACL carryback – Surplus implications, PAS election & application of Bill C-48 transitional rules This is in reply to your correspondence of December 8, 2014, wherein you requested our assistance in respect of the surplus implications of a "foreign accrual capital loss" ("FACL") carryback in the context of a given set of facts. ... The relevant part of paragraph 79(2)(a) of Bill C-48 reads as follows, as modified to incorporate the relevant deadlines that would be applicable in the context of the facts submitted (see text underlined): (…) if the corporation (…) elect in writing under this paragraph in respect of all of their respective foreign affiliates and file the election with the Minister of National Revenue on or before the day that is the later of (…) the filing-due dates for their taxation years that include the day on which this Act receives royal assent [June 30, 2014] and the day that is one year after the day on which this Act receives royal assent [June 26, 2014], subsections 5901(2) to (2.2) of the Regulations, as enacted by subsection (1), apply to dividends paid after December 20, 2002 by all the respective foreign affiliates of the elector corporations (…) In the context of the present case, the election for the PAS election rules to apply to the 2010-Dividend would have to have been made on or before June 30, 2014. ...

7 January 1992 Income Tax Severed Letter 9134185- Maintenance payments — adult child — third parties Unedited CRA Tags 60(b), 60(c), 60.1(c), 60.1(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. ... Subject: MAINTENANCE PAYMENTS ADULT CHILD THIRD PARTIES Section(s): 60(b), 60(c), 60.1(c), 60.1(1)] January 7, 1992 Appeals Branch Business and General Appeals & Referrals Division Division K. ...

18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6- 2015 STEP – Q2 – Meaning of Graduated Rate Estates CRA Tags 248(1) Principal Issues: CRA comments requested on meaning of graduated rate estate, including what property is included & what happens when there are 2 wills. ...

27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business Unedited CRA Tags 84(2), 120.4(1), 120.4(1.1), 125(7), 248(1) Principal Issues: Comparison of CRA’s response to question 7 of the 2018 STEP CRA Roundtable (2018-074403) and examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults. ... CRA Roundtable Question 10: TOSI – Excluded Shares and Related Business In question 7 of the 2018 CRA Roundtable of the Society of Trust and Estate Practitioners (“STEP”) the following question was asked: “Assume that a corporation has no business income because it derives income from property (possibly rental income from real property where the activities are not sufficient to constitute business income). ... Yet, even if it has been determined – taking into account the assumption made in Question 7 – that the shares of the capital stock of the corporation could not qualify as excluded shares, an amount received from this corporation by a specified individual would nevertheless be an excluded amount in respect of the specified individual. ...

18 June 2015 STEP Roundtable Q. 15, 2015-0572151C6- 2015 STEP – Q15- Tax Audit & Net Worth Statements CRA Tags 241 231.1(1) Principal Issues: Can CRA comment on auditors requesting personal financial information and/or furnishing statements of net worth of the shareholders of Canadian corporations? ... STEP CRA Roundtable – June 18 2015 Question 15. Tax Audit and Net Worth Statements Can CRA comment on the following: a) It has come to our attention that CRA is increasingly requesting personal financial information of the shareholders of Canadian corporations which are selected for audit. ...

10 January 1993 Income Tax Severed Letter 9321447- Yukon Indians — Lands Set Aside — Moratorium Unedited CRA Tags 81(1)(a) 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. ...

19 October 2023 External T.I. 2023-0974081E5- METC – Purchase price & installation of generator Unedited CRA Tags ITA: Section 118.2, subsection 118.2(2); paragraphs 118.2(2)(i), (l.2), and (m). ...

7 August 1990 Income Tax Severed Letter- Cape Breton Investment Tax Credit Program — date of acquisition of property — foreign exchange rate Unedited CRA Tags none Subject: Cape Breton Investment Tax Credit (CBITC) Program_ Date of Acquisition of Property-Foreign Exchange Rate This is in reply to your Memorandum dated March 13, 1990 whereby you requested our opinion concerning the determination of the date of acquisition of certain equipment and the treatment of variations in exchange rates in respect of part of the purchase price paid before the date of acquisitions of the equipment. ... As stated in paragraph 6 of IT-50R: “... property can pass and acquisition take place only if the asset is in existence and, even then, only if it is a `specific asset', i.e. one that is capable of being identified as the object of the contract.” ...

7 August 1991 Income Tax Severed Letter- Nova Scotia R & D Tax Credit- Ontario R & D Super Allowance Unedited CRA Tags 12(1)(x), 37(1)(d), 127(9), 127(11.1) Dear Sirs: Re: Nova Scotia Research and Development (`R&D') Tax Credit Ontario R&D Super Allowance We are writing in reply to your letter of June 3, 1991 in which you requested a technical interpretation as to why the Nova Scotia R&D Tax Credit is considered to be government assistance for the purpose of paragraph 12(1)(x) of the Income Tax Act (the "Act") while the Ontario R&D Super Allowance is not. ...

15 November 2006 External T.I. 2006-0190041E5 F- Biogas / Codigestion Process / Produced for Sale Unedited CRA Tags Schedule II 43.1 43.2 Principal Issues: In a given fact situation, where the taxpayer produces biogas through a digester using a codigestion process (manure and other substances) and where the biogas production is purified into methane in part for sale, whether (1) the digester is property that could be included in class 43.1? ... En outre, ce matériel admissible acheté avant 2012 sera inclus dans la nouvelle catégorie donnant droit au taux de DPA de 50 %. ... Vos questions Votre première question est de savoir si le " digesteur " utilisé dans le Projet pour produire du biogaz par le procédé de "co-digestion" pourrait être considéré un bien de la catégorie 43.1 de l'annexe II du Règlement? ...