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6 November 2003 External T.I. 2003-0039525 F- Canadian Renewable & Conservation Expenses-- summary under Subparagraph (d)(viii) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 43.1- Paragraph (d)- Subparagraph (d)(viii) computers used in operating landfill biogas site might be Class 10 property, and applications software would be Class 43.1 or Class 12 property/ below-surface pipes would not qualify A corporation implementing a Canadian renewable and conservation expenses (CRCE) project that uses landfill sites, and injects them with bacteria to produce recoverable gas, puts a structure (pipes) into the ground to recover the gas. ... (d)(viii) of Class 43.1 then referred only to above-ground equipment, CCRA stated: Expenses of a capital nature incurred in respect of property that is not surface equipment (e.g., equipment buried in the ground) would not be covered by subparagraph (d)(viii) …. ... CCRA responded: [S]ubparagraph (d)(viii) of Class 43.1 … specifically excludes property otherwise included in Class 10. ...

13 November 2014 External T.I. 2014-0535041E5 F- Bien de remplacement – Location d'immeubles-- summary under Paragraph 44(5)(a.1) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(a.1) rental property use before and after satisfies test A couple who co-owned various rental properties received insurance proceeds on the complete destruction of one of the properties, and purchased chalets in a resort area for rental use. ... CRA responded (TaxInterpretations translation): Even though the physical characteristics of the new properties would not be identical to those of the previous properties, the properties appear to be of the same nature (rental properties) and to be put to the same use (rental). … [T]he use made by the taxpayers of the new properties can be considered as an identical or similar use as they made of the previous property, for purposes of paragraph 44(5)(a.1). ...

16 November 2015 External T.I. 2015-0595041E5- Mutual Fund Trusts & 108(2)(a)(i)-- summary under Paragraph 108(2)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(2)- Paragraph 108(2)(a) MFT that is redeemable on demand for securities' (and s. 108(2)(a)) purposes with 2 redemption windows annually Where a provincial securities commission has a policy on what it considers to be redeemable on demand, will CRA generally accept such policy in determining whether the redeemable-on-demand requirement in s. 108(2)(a)(i) is satisfied? CRA responded: [W]here a provincial securities commission has a policy concerning what it considers to be redeemable on demand for provincial securities purposes [CRA]…will generally accept such policy in determining whether a particular trust would satisfy the redeemable on demand requirement in subparagraph 108(2)(a)(i). …. ...

20 June 2006 External T.I. 2005-0149651E5 F- CEE / FEC-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) expenditures to ensure safety of exploration personnel generally qualify if not specifically excluded The results of preliminary exploration work indicated that further exploration of the “Property” was warranted – but this would require work on the Property to make it safer before geologists could perform the additional work. ...

28 September 2006 External T.I. 2006-0197841E5 F- Shareholders agreement & 256(1.4)-- summary under Subparagraph 251(5)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b)- Subparagraph 251(5)(b)(i) technically a contingent right to acquire control where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares Four unrelated individuals (A, B, C and D) each hold 25% of the shares (being common shares) of Opco through their respective wholly-owned holding companies (Aco, Bco, Cco and Dco). ... After referencing IT-64R4, para. 37, CRA stated: It appears to us that subsection 256(1.4) would technically apply in the situation described …. ...

19 October 1999 External T.I. 9925055- GAINS & LOSSES ON OPTIONS-- summary under Options Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ... The trust in such an arrangement is a separate person for income tax purposes and therefore a stock call written outside an RRSP … would constitute a naked option. ...

7 July 2003 External T.I. 2001-0091415 F- Income & Losses from Bus. or Prop. ... For example, if a 30 year old Buyer died at age 75, the site could only be used for 54 additional years until the 99 th anniversary of the agreement – at which point the remains would be removed and buried (unless the agreement was renewed). ...

7 July 2003 External T.I. 2001-0091415 F- Income & Losses from Bus. or Prop. ... For example, if a 30 year old Buyer died at age 75, the site could only be used for 54 additional years until the 99 th anniversary of the agreement – at which point the remains would be removed and buried (unless the agreement was renewed). ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subsection 12(2.2) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(2.2) s.12(2.2) election can be made re s. 12(1)(x)(iv) inclusion for forgivable CEBA loan The Canada Emergency Business Account (“CEBA”) program provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... A taxpayer not qualifying for the 25% forgiveness who settles the loan for 100% of the principal may generally claim a deduction under s. 20(1)(hh) equalling the previous s. 12(1)(x) inclusion – even where the taxpayer made the s. 12(2.2) election. ...

15 June 2015 External T.I. 2014-0525501E5- Royalty payments & the US or UK Treaties-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 fees paid to the U.S. or U.K. for access to customer lists were exempt royalties Canadian-resident UserCos, who use existing confidential lists of the names and addresses of customers who have purchased certain types of products (“Lists”) for marketing purposes, pay CanCo fees based upon their use of the Lists. ... Turning first to the US Treaty, CRA stated: [T]here has not been a transfer of ownership of the information, but simply permission has been granted to use the information on the Lists for an approved purpose…[so that] the payment can be said to be “for the use of or the right to use…” the information on the Lists. … [T]he OwnerCos have information in their possession due to their special knowledge and experience and there is little that needs to be done to meet the request by CanCo to provide the Lists. ... Therefore… the Lists constitute “information concerning industrial, commercial or scientific experience”…. … CanCo (the payer) is a resident of Canada and therefore, it is our view that the payment arose in Canada. ...