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8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6- Qualifying person & multiple shares-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A The correspondent noted that in Canada, if each class of shares of a public company with multiple classes must be considered separately for purposes of satisfying the de minimis or 10-percent tests in the U.S. tax regulations (treated as being applicable for Canadian purposes under para. 2(c) of the "qualifying person definition) very few Canadian corporations with multiple classes of voting shares will be considered "qualifying persons" for purposes of the LOB clause. ...

5 September 2002 External T.I. 2002-0147315- PARTNERSHIP AS A PARTNER & 98 (3)-- summary under Subsection 98(3) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(3) lower-tier partnership wind-up Can s. 98(3) be used where one (or all) of the partners in the particular partnership are themselves partnerships? ...

24 March 2005 Internal T.I. 2005-0115921I7- Specified debt obligations & loan originating cost-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract debt definition- includes conditional sales contracts Conditional sales contracts purchased by a corporation likely would qualify as "debt obligations," so that the corporation would qualify as a restricted financial institution, i.e., a corporation whose principal business was the purchasing of debt obligations issued by arm's length persons. ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit-- summary under Subsection 126(2) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(2) The Directorate agreed that the taxpayer, which was a Canadian maunufacturer transferring some of its goods to a Japanese branch for sale there, was overstating its profits for purposes of s. 126(2), by treating most or all of the profits on the sale of such products as being profits of the Japanese branch. ...

2012 Ruling 2011-0429961R3- Hydrocarbon & Immovable property: Canada-UK Treaty-- summary under Subsection 116(6.1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(6.1) Ruling that the transfer of shares of a UK company (Forco2) by two other UK companies (Forco1 and Forco4) would be exempt under Art. ...

2012 Ruling 2011-0429961R3- Hydrocarbon & Immovable property: Canada-UK Treaty-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 storage business carried on in leased real estate had over 50% of value Ruling that the transfer of shares of a UK company (Forco2- whose value is derived from CAnco shares) by two other UK companies (Forco1 and Forco4) would be exempt under Art. ...

3 June 2011 STEPs Roundtable Q. 2, 2011-0401831C6- 2011 STEP Conference-Q2-Trusts & Principal Res.-- summary under Subsection 107(4.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(4.1) where a cottage is contributed to an inter vivos trust by a Canadian-resident individual (B) who is one of the beneficiaries, then the s. 107(2) rollover will be available if the cottage is distributed to B out of the trust (e.g., in advance of the 21-year deemed disposition date under s. 104(4), given that B will be "the person...from whom the particular trust...received the property); however, the rollover will be available if the cottage is distributed out to another capital beneficiary (D) at a time that the contributor (B) is still living as the quoted condition will be satisfied. ...

26 July 2012 External T.I. 2011-0431681E5- Taxable Benefits – Recreational Facilities-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) CRA stated: [A] taxable benefit would not generally arise in situations where an employer provides an in-house recreational facility and the facility or membership is available to all employees. ...

4 March 2015 External T.I. 2014-0537941E5- Non-Profit Organization – fibre-optic cable-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) substantial fibre-optic cable network likely not consistent The Institute, a not-for-profit organization, received a provincial grant and subsequently accessed provincial debentures to finance the construction of a substantial fibre-optic cable network. ...

6 December 2012 External T.I. 2012-0461711E5 F- Paiements indirects / Indirect payments-- summary under Subsection 56(2) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(2) 56(2) inapplicable to incorporated artist respecting producer paying mandatory contributions to the fund for the artist’s union A producer who retains the services of an incorporated performing artist is required to pay a percentage of the fees otherwise payable by it to the artist’s Corporation (respecting the services performed by the artist as an employee of the Corporation) directly to the benefits plan (the “CSA”) for the Union des Artistes (UDA). ...