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24 March 1994 External T.I. 9335755- RRIF PAID TO UK RESIDENT- PENSION & ANNUITY (U4-100-17)-- summary under Article 18 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 18 Notwithstanding the definition for "annuity" found in s. 5 of the Income Tax Conventions Interpretation Act, a payment out of a RRIF which qualifies as a "periodic pension payment" under the ITCIA which is paid to a resident of the UK, falls under the term "pension" in paragraph 3 of Article XVII of the UK Convention. ...

6 June 1994 External T.I. 9337485- Partie XIII — Droit d'utilisation de logiciels information-- summary under Subparagraph 212(1)(d)(i) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(1)- Paragraph 212(1)(d)- Subparagraph 212(1)(d)(i) The position of Revenue Canada that a payment for the use of, or the right to use, software in Canada is caught by s. 212(1)(d)(vi) applies even if the payment is made as a lump sum rather than periodically. ...

23 July 1996 External T.I. 9612365- ARTICLE XI(4) & "INCOME ASSIMILATED TO INCOME"...-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 A payment by a credit union to a member, in respect of a share of capital stock, which is deemed to be interest by s. 137(4.1) of the Act will be considered to be interest for purposes of Article XII of the Canada-U.S. ...

23 November 1993 External T.I. 9322405 F- SR & ED-- summary under Subsection 37(1) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1) Where a non-resident company makes charges in the form of technical fees, royalties or licence fees to a Canadian taxpayer for the right to manufacture or produce a product developed as a result of SR&ED previously performed in Canada, this will not jeopardize the eligibility of the Canadian taxpayer for the ITC. ...

26 July 1995 External T.I. 9501585- court ordered partition & sale disposition-- summary under Subsection 44(1) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(1) Where as a result of the bankruptcy of one of the four co-tenants of rental properties, a court-appointed trustee receives court approval for severance, partition and sale of the property, the non-bankrupt co-tenants would be entitled to utilize s. 44(1) in respect of their proceeds (in this case, property interests in other co-owned buildings). ...

29 March 2001 External T.I. 2001-0074145- Affiliated persons & stop loss rules-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Where the shares of a corporation are owned equally by four trusts having the same corporate trustee, s. 40(3.6) will apply to deny a capital loss arising on the redemption of the shares of one of the trusts. ...

29 March 2001 External T.I. 2001-0074145- Affiliated persons & stop loss rules-- summary under Subsection 40(3.6) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.6) Where the shares of a corporation are owned equally by four trusts having the same corporate trustee, s. 40(3.6) will apply to deny a capital loss arising on the redemption of the shares of one of the trusts. ...

7 January 2003 External T.I. 2002-0133675- Cash Call Provisions & Contingent Rts-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) Ss.251(5)(b) and 256(1.4) applied to a shareholders agreement that provided that where one of the shareholders failed to advance money to the company following an operating fund deficiency, the other shareholders could choose to advance the funds which the defaulting shareholder had failed to advance, in which event the defaulting shareholder would have its equity diluted. ...

8 November 1999 External T.I. 9914135- INTEREST & PENALTY RE MICHIGAN SBT-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Penalties in respect of the Michigan single business tax do not meet all the conditions specified in IT-104R2, para. 3 and therefore, unless the facts show otherwise, are not deductible. ...

1 March 2001 External T.I. 2000-0050275 F- Remboursement de prime / enfant infirme-- summary under Subsection 146(8.1) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8.1) overview or rules for transfer of taxpayer’s RRSP on death to financially dependent child Regarding whether the taxpayer’s RRSP could be transferred upon death to the taxpayer’s daughter free of tax, CCRA discussed the rules under ss. 146(8.9) and (8.1) for the transfer to a financially dependent child. ...