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17 June 2013 External T.I. 2013-0486901E5- Petroleum & Natural Gas Lease CRA Tags 66(15) "Canadian resource property" 66.4 Principal Issues: How is an amount received for granting a lease of rights to explore for, drill for or extract petroleum, natural gas or other hydrocarbons reported for income tax purposes? ... Yours truly, Fiona Harrison, CPA, CA Manager, Resources Section Reorganizations Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

22 October 2013 External T.I. 2013-0503311E5- Class. of steel tanks & oak barrel for CCA purpose CRA Tags 125.1(3) "manufacturing or processing" ITR 1109 "manufacturing or processing" ITR Schedule II- Class 8 ITR Schedule II- Class 29 ITR Schedule II- Class 43 Principal Issues: Whether steel tanks and oak barrels used for fermenting/clarifying/blending and/or aging wine, and acquired after March 18, 2007 and before 2016, would be included in class 29 of Schedule II of the Income Tax Regulations. ... For further discussion in this regard, see IT-147R3, "Capital Cost Allowance – Accelerated Write-Off of Manufacturing and Processing Machinery and Equipment", which is available on the CRA's website. ...

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves CRA Tags 110.6(1) 110.6(2) 66.4(5) 66(15) 110.6(1.3) 248 Principal Issues: Whether the taxpayer's farm would continue to meet the definition as a "qualified farm property", if oil reserves are discovered on the property. ... Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

10 June 2015 External T.I. 2015-0580531E5- joint account & estate returns CRA Tags 104(13) 70(5) Principal Issues: TREATMENT OF PROPERTY HELD IN JOINT OWNERSHIP AT DEATH Position: LEGAL DETERMINATION REQUIRED Reasons: TAX TREATMENT DEPENDS ON LEGAL & BENEFICIAL OWNERSHIP OF THE PROPERTY. ...

16 November 2015 External T.I. 2015-0595471E5- Partnerships & capital gains reserve CRA Tags 96(1) 40(1) Principal Issues: Is a capital gains reserve under subparagraph 40(1)(a)(iii) claimed at the partner or partnership level? ... Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

20 February 2012 External T.I. 2011-0421581E5- Payments to Day Homeshare Providers & 81(1)(h) Unedited CRA Tags ITA 81(1)(h) Principal Issues: Whether the per diem payments received by the "day" homeshare providers fall under paragraph 81(1)(h) income tax exemption. ... In that case, Estey, J. concluded that "... one is ordinarily resident in the place where, in the settled routine of his life he regularly, normally or customarily lives". ...

27 April 2011 External T.I. 2010-0368141E5- Principal Residence- Trust & 1/2 hectare rule Unedited CRA Tags 54 "principal residence", 40(2)(b), 70(5) Principal Issues: With respect to determining whether the land in excess of one-half hectare was regarded as necessary to the use and enjoyment of the housing unit as a residence, can the factors utilized on the deemed disposition of the residence upon the mother's death be attributed to the same determination when the residence is disposed of by the mother's estate? ... Yours truly, Steve Fron Acting Manager International & Trust Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

12 January 2012 External T.I. 2011-0415991E5- OETC Eligibility & evacuation from foreign country Unedited CRA Tags 122.3 Principal Issues: Whether employees otherwise qualify for OETC pursuant to 122.3(1) when evacuated back to Canada during the qualifying period when they are teleworknig in connection with the foreign worksite from a location in Canada, or not working in Canada but "on call" to return to the foreign worksite at the request of the employer. ... Yours truly, Robert Demeter Manager, International Section I International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

17 February 2017 External T.I. 2016-0662341E5- Airline passes – retired and current employees For French version, see 2016-0669931E5 F Unedited CRA Tags ITA: 6(1)(a) Principal Issues: Whether the CRA’s administrative policies concerning standby airline passes provided to current airline employees and standby and space-confirmed airline passes provided to retired airline employees are still valid? ... Generally, under paragraph 6(1)(a) of the Act “the value of board, lodging, and other benefits of any kind whatever received or enjoyed … in respect of, in the course of, or by virtue of the taxpayer’s office or employment” is included in an employee’s income. ...

24 November 2008 External T.I. 2007-0228301E5- FAPI & Capital Dividend Account Unedited CRA Tags 91(1); 89(1)- CDA; 12(1)(k) Principal Issues: Whether FAPI of a foreign affiliate of a corporation can be added to the corporation's capital dividend account when the FAPI was derived from capital gains of the foreign affiliate? ... For Director International & Trusts Division Income Tax Rulings Directorate ENDNOTES 1 Unless otherwise stated, statutory references in this letter are to the Income Tax Act, R.S.C. 1985 (5th Suppl.) c. 1, as amended to the date hereof. ...