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28 January 2022 External T.I. 2020-0860211E5- Principal Residence Exemption – Unedited CRA Tags Paragraph 54(e)- definition of principal residence and land in excess of one-half hectare; 40(2)(b) Principal Issues: Whether the taxpayers are eligible to claim the principal residence exemption on the portion of their land in excess of one-half hectare. ... Foggia, CPA, CA January 28, 2022 Dear XXXXXXXXXX: Re: Principal Residence Exemption – Excess Land This is in response to your correspondence of August 4, 2020 and a subsequent telephone conversation (Couvrette/XXXXXXXXXX) of August 25, 2020, wherein you requested our views concerning the disposition of a residence where the total area of the land upon which the housing unit is situated exceeds one-half hectare. ...

5 December 2022 External T.I. 2021-0915921E5- ELHT – Class of beneficiaries Unedited CRA Tags 144.1(2)(e) and (f) Principal Issues: Whether a group comprised of employees from multiple participating employers who are entitled to different benefit entitlements may constitute a class of beneficiaries for purposes of subparagraph 144.1(2)(e)(i) of the Act. ... Zabolotney December 5, 2022 Dear XXXXXXXXXX: Re: Employee Life and Health Trusts – Class of beneficiaries We are writing in reply to your correspondence of November 3, 2021, wherein you asked for our comments regarding the beneficiary class rules in paragraph 144.1(2)(e) of the Income Tax Act (the ”Act”). ...

31 July 2019 External T.I. 2019-0798361E5- Business use of vehicles – maintenance employees Unedited CRA Tags 6(1)(a) Principal Issues: Whether maintenance employees travel would be considered personal in various circumstances. ... XXXXXXXXXX 2019-079836 Sarah Springate July 31, 2019 Dear XXXXXXXXXX: Re: Business use of vehicles – maintenance employees We are writing in response to your correspondence of February 27, 2019 and our (Springate/XXXXXXXXXX) subsequent telephone conversation of June 3, 2019, in which you requested clarification as to whether the travel of certain maintenance employees in employer provided motor vehicles (the Vehicles) would be considered personal in certain circumstances. ... For further information on keeping records, please refer to Chapter 2 – Automobile and motor vehicle benefits and allowances of the CRA’s Guide T4130, Employers’ Guide Taxable Benefits and Allowances. ...

4 March 2015 External T.I. 2014-0537941E5- Non-Profit Organization – fibre-optic cable CRA Tags 149(1)(l) Principal Issues: Whether the income generated from the fibre-optic cable network would jeopardize the not-for-profit status of the Institute. ... XXXXXXXXXX 2014-053794 Ananthy Mahendran (905) 721-5204 March 4, 2015 Dear XXXXXXXXXX: Re: Non-Profit Organization – Revenue from the Fibre-Optic Cable Network This is in response to your email of June 20, 2014, requesting our comments on the application of paragraph 149(1)(l) of the Income Tax Act (the "Act") to XXXXXXXXXX ("the Institute"). ...

12 March 2015 External T.I. 2014-0541991E5- Objection – Eligible Dividend Designation Principal Issues: 1. ... Ng (416) 512-4013 March 12, 2015 Dear XXXXXXXXXX, Re: Objection – Eligible Dividend Designation We are replying to your letter of August 1, 2014 in which you requested our comments with respect to the manner in which a taxpayer can make a late eligible dividend designation in the event that an assessment by the Canada Revenue Agency (the "CRA") which causes the taxpayer's general rate income pool ("GRIP") balance to increase is upheld at the end of the appeals process. ...

21 November 2005 External T.I. 2005-0143231E5- Terminal Charge / ONT Tax Reduction Unedited CRA Tags 6(2) Principal Issues: (a) The taxable status of a $XXXXXXXXXX terminal loss incurred by an employer in respect of a leased automobile at the end of the lease- should the entire amount of the terminal loss be included in the employee's income as a taxable benefit? ... Randy Hewlett XXXXXXXXXX 613-957-2049 2005-014323 November 21, 2005 Dear XXXXXXXXXX: Re: Automobile Benefit / Ontario Tax Reduction We are writing in response to your letter of April 30, 2005, which was sent to the CRA's Summerside Taxation Center. ...

29 October 2020 External T.I. 2020-0835681E5- Indian Act Exemption – Employment Income Unedited CRA Tags 81(1)(a); Indian Act s.87 Principal Issues: Are the employees (those working at the field office and those doing XXXXXXXXXX) exempt from income tax pursuant to Guideline 2? ... Gauthier October 29, 2020 Dear XXXXXXXXXX: Re: Indian Act Exemption for Employment – Guideline 2 This is in reply to your email dated January 7, 2020 where you asked whether employees of a partnership would be exempt from tax pursuant to Guideline 2 of the Indian Act Exemption for Employment Income Guidelines. ...

6 March 2023 External T.I. 2023-0960671E5- Carriage house & multigenerational home renos Unedited CRA Tags The definition of "qualifying renovation" and "secondary unit" in subsections 122.92(1). ... El-Kadi March 6, 2023 Dear XXXXXXXXXX: Re: Multigenerational home renovation tax credit – building a carriage house as secondary unit We are writing in response to your email of January 12, 2023, in which you asked whether the multigenerational home renovation tax credit (MGHRTC) would apply to the construction of an accessory dwelling unit such as carriage house or a laneway house. ...

19 December 2023 External T.I. 2023-0974871E5- METC-Interocular lens & prepaid medical expenses. ... Underhill, CPA, CGA December 19, 2023 Dear XXXXXXXXXX: Re: Amounts paid for interocular lens & prepaid medical expenses We are writing in response to your correspondence received on February 14, 2023, asking whether the cost you incurred for an interocular lens as part of cataract surgery qualifies as an eligible medical expense for the purposes of the medical expense tax credit (METC). ...

5 March 2024 External T.I. 2023-0962831E5- Active business income – Income from solar panels Unedited CRA Tags 125(1), 125(7) “income of the corporation for the year from an active business”, “active business carried on by a corporation”, “personal services business”, “specified investment business”, 129(4) “income or loss”, 248(1) “business”, “property" Principal Issues: Whether income earned by a corporation from selling electricity generated from solar panels would be active business income eligible for the small business deduction pursuant to subsection 125(1) of the Income Tax Act. ... XXXXXXXXXX Income Tax Rulings Directorate Ryan Wallace, CPA 2023-096283 March 5, 2024 Dear XXXXXXXXXX: Re: Active Business Income – Income received from selling electricity generated from solar panels We are writing in response to your email of February 3, 2023, wherein you requested our views on whether income earned by a Canadian-controlled private corporation (the “Corporation”) from selling electricity generated from solar panels would be considered active business income (“ABI”) eligible for the small business deduction (“SBD”) in subsection 125(1) of the Income Tax Act (“Act”). ...