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4 May 2005 External T.I. 2005-0120271E5 F- Change of Control- CDA & RDTOH-- summary under Clause 256(7)(a)(i)(A) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(7)- Paragraph 256(7)(a)- Subparagraph 256(7)(a)(i)- Clause 256(7)(a)(i)(A) s. 256(7)(a)(i)(A) applied where taxpayer acquired shares of CCPC from his sister Ms. ...

6 October 2017 APFF Roundtable Q. 1, 2017-0708971C6 F- Inactive Corporations & subs. 162(7) ITA-- summary under Paragraph 150(1)(a) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1)- Paragraph 150(1)(a) requirement for Canco to file nil T2 returns, but no penalty What was the CRA position on: (a) the obligation of an inactive Canadian corporation to file a T2 return for each of the years in which there is no business activity and, thus, no tax payable; and (b) the application of late-filing penalties? ...

6 July 2018 External T.I. 2018-0759521E5- Tax on split income & preferred beneficiary-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (c) income to preferred beneficiary is not split income A trust that is a limited partner of a partnership (“LP”) providing back office support to a general partnership of accounting professionals (“Partnership”) as its only source of income has a minor disabled beneficiary who qualifies as a “preferred beneficiary.” ...

6 July 2018 External T.I. 2018-0759521E5- Tax on split income & preferred beneficiary-- summary under Subsection 104(14) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(14) split income rules do not apply to preferred beneficiary income The definition of split income includes trust income distributions under s. 104(13) but not preferred beneficiary amounts under s. 104(14). ...

5 April 2018 Internal T.I. 2017-0728581I7- Ss 125(3.2) & 125(8) amending the business limit-- summary under Paragraph 125(3.2)(d) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(3.2)- Paragraph 125(3.2)(d) business limit allocation may be amended within statute-barring period In essentially confirming 2009-0351721E5 to the effect that an associated group of Canadian-controlled private corporations can file amended T2 Schedule 23s provided that the amended allocation agreement does not change the amount allocated to any associated corporation for a taxation year for which a reassessment is statute-barred, CRA stated: [P]aragraph 125(3.2)(d) provides that both CCPCs must file a prescribed form with the Minister in their return of income for their respective taxation years for the assignment to be valid. ...

1 September 1994 External T.I. 9413775- ELIGIBLE PROPERTY & CUM DIVIDENDS-- summary under Subsection 85(1.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1) right to accrued but undeclared dividends was not a separate eligible property from the preferred shares Before indicating that a preferred share with accrued cumulative dividends could be transferred by an individual to a holding corporation under s. 85(1) or exchanged for other shares of the corporation pursuant to a reorganization of capital described in s. 86(1) without the accrued dividends being recognized as income, Revenue Canada rejected the position that such accrued dividends would be an eligible property separate form the shares themselves, stating: The right to accrued cumulative dividends would be just one of the bundle of rights that would be attached to a particular share.... ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)-- summary under Paragraph 250(1)(a) Summary Under Tax Topics- Income Tax Act- Section 250- Subsection 250(1)- Paragraph 250(1)(a) "It is a question of fact whether a taxpayer, who is a resident of a foreign country and who is present in Canada for more 182 days in a year, sojourns in Canada for more than 182 days in that year. ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 "Where a U.S. resident who is not a factual or deemed resident of Canada exercises his employment in Canada, his employer... is required to withhold source deductions in respect of the employment under subsection 153(1) of the Act even if the remuneration received by such an individual is exempt from Canadian taxation by virtue of paragraph 2 of Article XV of the Convention. ...

16 July 1996 External T.I. 9604915- 55(2)-NOT APPLY WHERE SALE & REDMPTION DIFFERENT SERIES.-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Where preferred shares issued by Newco on the roll-in to Newco of shares of Opco, have a dividend entitlement equal to dividends received by Newco on the shares of Opco, and to proceeds received by Newco on the sale of shares of Opco to the extent of the gain realized by Newco, but with the redemption amount of the shares being reduced on a dollar-for-dollar basis by the amount of the dividends paid out of such gain. ...

7 May 1995 Internal T.I. 9510220- PART I.3, O/S CHEQUES & OVERDRAFTS-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Bank overdrafts are considered to have arisen to the extent that they have been utilized or drawn upon. ...