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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. ...
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. ...
Article Summary
Hersh Joshi, Jack Silverson, "Understanding and Doing Business with Tax-Exempt Entities", 2018 Conference Report (Canadian Tax Foundation), 29:1 – 35 -- summary under Clause 149(1)(o.2)(ii)(A)
Hersh Joshi, Jack Silverson, "Understanding and Doing Business with Tax-Exempt Entities", 2018 Conference Report (Canadian Tax Foundation), 29:1 – 35-- summary under Clause 149(1)(o.2)(ii)(A) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(A) Issues where co-investing in real estate (pp. 29:18-19) [A] pension plan may want to co-invest…[and] might establish a real estate corporation…. … If the real estate corporation performs any activities in relation to the real estate property, a concern may arise as to whether the real estate corporation has satisfied the requirement of subclause 149(1)(o.2)(ii)(A)(I), given that it would be performing activities on a real estate property part of which is not owned by the corporation, by another real estate corporation, or by a registered pension plan. … [Subsequently to … 9401608, CRA] stated that it had re-examined its position and was now of the view that a co-ownership situation would not jeopardize a real estate corporation’s tax status. Further, the CRA provided that the activities carried on by the real estate corporation in relation to the co-owned property should be proportionate to the interests held by “qualified” entities under subclause 149(1)(o.2)(ii)(A)(I) (that is, by the real estate corporation, by another real estate corporation, or by a registered pension plan) …. … Pension plans looking to co-invest in real estate property may want to avoid these issues by using a structure…. ...
News of Note post
But the purchase price was a once-and-for-all payment for the acquisition of an asset of enduring advantage – the 18 GMEs – which once acquired formed part of the profit-earning structure of the Trustee's business. ... Summaries of Commissioner of Taxation v Sharpcan Pty Ltd [2019] HCA 36 (High Court of Australia) under s. 18(1)(b) – Capital Expenditure v. Expense – Contract Purchases and Concessions and Licences, and s. 13(34)(b). ...
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. ...
Technical Interpretation - External summary
3 February 2005 External T.I. 2005-0111871E5 F - Intérêts / mise à part de l'argent -- summary under Subparagraph 20(1)(c)(i)
3 February 2005 External T.I. 2005-0111871E5 F- Intérêts / mise à part de l'argent-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) cash damming to pay current deductible business expenses is an eligible use which continues with the business Regarding the deductibility of interest on borrowed money used for current business expenses in a cash damming context, CRA stated: Where the borrowed money is used to pay a current expense that is incurred for the purpose of earning business income and is deductible … the test of a direct connection is satisfied in the year the expense is incurred and in subsequent years. … [I]nterest on borrowed money used to pay a current expense incurred to earn business income will continue to be deductible as long as the source of income, the business, does not disappear. However, the provisions of section 20.1 could, depending on the case, allow the interest to be deductible after the source of income has disappeared. … [T[he total value of the assets of the business is not a criterion for determining whether interest on borrowed money used to pay a current expense incurred to earn business income is deductible. ...
Technical Interpretation - Internal summary
26 February 2025 Internal T.I. 2023-0985151I7 F - Remboursement de frais juridiques par un actionnaire à sa société / Reimbursement of legal fees by a shareholder -- summary under Legal and other Professional Fees
At the same time, they agreed that if a legal proceeding of the corporation to obtain damages to compensate for lost income resulted in the receipt of damages, he would receive a dividend on his preferred share that was a percentage of the damages – but that if the law suit was unsuccessful, he would agreed to reimburse the corporation for certain legal fees related to the litigation. ... Regarding whether the individual could deduct his reimbursement payment, CRA stated. … Mr. A's undertaking to reimburse the legal costs of the corporation only took effect if the corporation received an unfavourable decision …. ...
Conference summary
7 October 2021 APFF Roundtable Q. 19, 2021-0901121C6 F - APFF – ITR Remissions -- summary under Audit and Assessment Procedure
7 October 2021 APFF Roundtable Q. 19, 2021-0901121C6 F- APFF – ITR Remissions-- summary under Audit and Assessment Procedure Summary Under Tax Topics- General Concepts- Audit, Filing and Assessment Procedure rate increase for rulings work Regarding its increases in the hourly rates for its rulings service, the Directorate stated: [T]he fee applicable to a File is currently $104.04 per hour for the first 10 hours and $161.26 per hour for each subsequent hour. … From April 1, 2022, the rate will be $221.24 per hour worked on a File and will increase to $281.22 per hour from April 1, 2023 [and thereafter] will … be increased annually in line with the CPI. ...