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Archived CRA website
ARCHIVED – Education Tax Measures – Study Abroad
ARCHIVED – Education Tax Measures – Study Abroad Archived content Information identified as archived is provided for reference, research or recordkeeping purposes. ... For more details please see our publication RC192, Information for Students – Educational Institutions Outside Canada. 5. ...
Archived CRA website
ARCHIVED – T4A Slip – Box 048
ARCHIVED – T4A Slip – Box 048 Archived content Information identified as archived is provided for reference, research or recordkeeping purposes. ... Previously, payments for fees for services were reported in Box 28 – Other income, along with many other types of income. ...
News of Note post
13 November 2018- 12:31am Iberville Developments – Quebec Court of Appeal finds that it is abusive to use rollover provisions to avoid rather than defer tax Email this Content Three affiliated Quebec corporations avoided (or so they thought) most of the Quebec tax on the sale of Quebec real estate at a gain of around $800M (including some recapture) by using a “Quebec year-end shuffle.” ... Agence du Revenu du Québec, Quebec Court of Appeal No. 500-09-026184-168 (November 12, 2018) under s. 245(4), s. 9 – capital gain v. profit – real estate and s. 18(1)(b) – capital expenditure v. expense – improvements v. running expenses. ...
Technical Interpretation - Internal summary
15 January 2007 Internal T.I. 2006-0216801I7 - Redemption of US $ Denominated Shares -- summary under Subsection 39(2)
15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) s. 39(2) application on USD pref redemption, cf. if USD common shares The redemption of U.S. ... However, the Directorate noted its previous comments that MacMillan Bloedel “ deals with the redemption of redeemable and retractable preferred shares, which may be viewed as similar to the repayment of a debt obligation” and it is “not prepared to extend the reasoning to a redemption of shares in general.” ...
Technical Interpretation - Internal summary
18 May 2022 Internal T.I. 2018-0788761I7 F - Amortissement – Travaux sur un bien loué et F&T -- summary under Subsection 1102(4)
18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(4) to be improvements or alterations to leasehold interest, property acquisitions must be assimilated to landlord’s property The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ... Regarding whether the costs of such work should be added to the cost of the taxpayer’s Class 13 leasehold interest pursuant to Reg. 1102(4) before regard was had to Reg. 1102(5), CRA stated: [A]n amount expended is for the making of improvements or alterations to a leased property within the meaning of subsection 1102(4) where such expended amount relates to property that is incorporated into the leased property and becomes the property of the lessor. … Generally, the owner of a building owns everything that is joined to the building. ...
Article Summary
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114 -- summary under Paragraph (c)
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Excluded Property- Paragraph (c) Initial concern re s. 95(1) – EP – para. (c) that property of the partnership could not qualify (pp. 20:56-59) When the EP definition was first proposed in 1982, the draft provision raised concerns that property of the partnership could not qualify as property of the FA. … The tax community expressed a concern that where an FA has an interest in a partnership that carries on an active business, the partnership interest of the FA could qualify as EP, but partnership property used for the purpose of gaining or producing income from an active business could not so qualify … [so] that where a partnership of which a foreign affiliate is a member disposes of capital property used principally for the purpose of gaining or producing income from an active business, the property does not qualify as excluded property …. … Although the current definition continues to refer to property “of the” FA, it has been accepted that the partnership postamble resolves the concern that arises where partnership property has been disposed of. ...
Technical Interpretation - Internal summary
18 May 2022 Internal T.I. 2018-0788761I7 F - Amortissement – Travaux sur un bien loué et F&T -- summary under Ownership
18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership leasehold improvements are assimilated to the landlord’s property unless the lease specifies otherwise Before quoting from Mount Robson in this regard, the Directorate indicated that: Generally, the owner of a building owns everything that is joined to the building. ...
Technical Interpretation - External summary
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- summary under Regulation 805
A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration inter alia for annual royalties payable out of any oil & gas production. ... A carries on a business through a PE in Canada and the oil & gas royalties are attributable to the PE, Part XIII… of the Act does not apply, and the company is not required to withhold tax…. ... The company is required to… use the exemption code "S" …. Where neither paragraph 805(a) nor (b)… apply, the annual royalties paid to Mr. ...
Technical Interpretation - External summary
23 January 2015 External T.I. 2013-0509771E5 - Oil & gas payments made to U.S. resident -- summary under F
23 January 2015 External T.I. 2013-0509771E5- Oil & gas payments made to U.S. resident-- summary under F Summary Under Tax Topics- Income Tax Act- Section 66.4- Subsection 66.4(5)- F FMV addition and subtraction where drilling rights are granted for royalty Mr. A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration for an upfront bonus of $100,000, and annual royalties payable out of any oil & gas production. ... However, the proceeds of disposition (i.e., $100,000 + $300,000) of the CRP (i.e. the drilling etc. rights given to the Canadian company) were subtracted from his CCOGPE pool under variable F. ...
Technical Interpretation - External summary
2 August 2013 External T.I. 2013-0475261E5 - Eligible Dividend - Late Filing 89(14.1) & 184(3) -- summary under Subsection 89(14.1)
2 August 2013 External T.I. 2013-0475261E5- Eligible Dividend- Late Filing 89(14.1) & 184(3)-- summary under Subsection 89(14.1) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(14.1) A Canadian-controlled private corporation makes a s. 184(3) election to deem the excess portion of a capital dividend to be a separate taxable dividend. ... CRA indicated that it would accept a late designation request made within three years, to the extent of a GRIP balance to support an eligible dividend designation, provided the following conditions are met: * The taxpayers took reasonable steps and care to comply with the requirements in respect of subsection 83(2) and the computation of the capital dividend account at the time that the capital dividend election was originally made; * The late designation request under subsection 89(14.1) was not specifically intended by the taxpayers at the time that the subsection 83(2) election was made nor does the late designation request form part of a series of requests made on a regular basis; and, * The late designation request does not involve aggressive tax planning. ...