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11 October 2017 External T.I. 2016-0660421E5- Foreign tax credit – former resident Unedited CRA Tags 126(2.21), 152(4)(b) and (c), 152(4.01), 152(6)(f.1) Principal Issues: Does subparagraph 152(4)(a)(ii) of the Act allow a taxpayer to file a waiver for an emigration year for the purpose of keeping the taxation year open indefinitely to allow the taxpayer to claim a foreign tax credit under subsection 126(2.21) beyond the statutory limits imposed under paragraph 152(4)(b)? ... Agarwal, CPA, CMA, MBA October 11, 2017 Dear XXXXXXXXXX: Re: Foreign tax credit – former resident This letter is in response to your emails dated July 4, 2016 and August 4, 2016, in which you seek clarification regarding the period within which the Minister may assess or reassess a taxpayer’s return of income with respect to a claim for a foreign tax credit under subsection 126(2.21) of the Income Tax Act (“Act”). ...

1993 External T.I. 9310110 F- CALU Ques. 13- Buy-Sell Agreement & Valuation of Shares Unedited CRA Tags 110.6(15)(b), 69 THE CONFERENCE FOR ADVANCED LIFE UNDERWRITING 1993 Annual Conference Question 13 As part of a buy-sell agreement among shareholders a corporation is the owner and beneficiary of life insurance policies on the lives of shareholders. ... Response (a)     The Department has not considered specifically whether such a dividend would reduce the fair market value of the shares, however, if the disposition of shares by the estate is governed by a bona fide buy-sell agreement among shareholders, its provisions should be determinative of value as stated in paragraphs 28 to 31 of Information Circular 89-3. ... (b)     Paragraph 110.6(15)(b) limits the fair market value of the insurance proceeds for the purposes of the definitions listed in the preamble to subsection 110.6(15). ...

/ Does a monthly payment of a fixed amount paid to employees using their personal cell phone in the performance of the duties of their employment represent a reimbursement or an allowance? Position Adoptée: Il s'agit d'une allocation. / The amount would be an allowance. ... Par conséquent, il ne peut pas s'agir d'un remboursement de dépenses. / The fact that the contract with the service provider must be given to the employer is not a proof of payment. ...

16 January 2008 External T.I. 2007-0260071E5- Instalment Interest & Penalties-Inter Vivos Trust Unedited CRA Tags 156 Principal Issues: Does the CRA assess instalment interest and penalties where an inter vivos trust does not make instalment payments? ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch cc. Joffrine Mailhot, T1/T3 Returns Processing Section, Processing Division, Individual Returns & Payments Processing Directorate, Assessment and Benefit Services Branch ...

Is the income earned by a farmer under a FIT / microFIT contract considered farming income? ... Is the income earned by a farmer for the rental of farmland to a third party who enters into FIT / microFIT contract considered farming income? ... Would the income earned by a farmer under items 1 & 2 be considered incidental to farming income? ...

1 November 1991 External T.I. 91M11285 F- "Flow Through" of Deductions for Expenditures on SR & ED to Limited Partners Unedited CRA Tags 37 NOVEMBER 1991 QUESTION 16B Does section 37 permit the "flow through" of deductions for  expenditures on scientific research and experimental development to limited partners in a partnership which carries on a research business? ... BowenSection 31CCM # 912594 ...

22 January 2013 External T.I. 2012-0445401E5- Eligible Dependent – Support by Court Order CRA Tags 118.5(b) Principal Issues: Does a father who is required to pay child support able to claim the eligible dependent, even when the court order so indicates? Position: No Reasons: Legislation & Court positions XXXXXXXXXX 2012-044540 George A. ... Yours truly, Sharmini Ratnasingham for Director Business & Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

Is the income earned by a farmer under a FIT / microFIT contract considered farming income? ... Is the income earned by a farmer for the rental of farmland to a third party who enters into FIT / microFIT contract considered farming income? ... Would the income earned by a farmer under items 1 & 2 be considered incidental to farming income? ...

18 April 2013 External T.I. 2013-0484631E5- Employee Bursary & Education Tax Credit CRA Tags Regulation 200(2) 6(1)(a) 118.5 118.6 Principal Issues: Change in position taken in Document 2012-043551 Position: ETC is in fact available to an individual taking a course in connection with his or her employment, provided all other requirements for the ETC are met. ... Yours truly, Sharmini Ratnasingham for Director Business & Employment Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

1993 External T.I. 9314270 F- Permanent Establishments & Independent Agents (4112-2-5) Unedited CRA Tags Treaty US Article V Corporate Management Tax Conference Canada-U.S. Income Tax Convention: Permanent Establishment & Independent Agent Question 5 Under the Canada-U.S. ...