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28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Paragraph 104(4)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(4)- Paragraph 104(4)(a) CRA generally will ignore any premium that could be attributed to controlling non-participating preference shares, for purposes of subsection 70(5) of the Income Tax Act (the "Act"), where the shares were held to protect the deceased's economic interest in the corporation. ...

3 March 2015 External T.I. 2014-0519981E5 F- Donation avec charge / Gift with a charge-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property real estate property is one property Before considering the treatment under ss. 69(1)(b)(ii) and s. 69(1)(c) of a gift of a real estate property that is charged with a hypothec, CRA stated: [A]n immovable is normally considered as a single and unique property at least where such property is not the object of a legal partition into two or more distinct properties. ...

5 October 2012 Roundtable, 2012-0453201C6 F- Règles d'attribution- séparation & décès-- summary under Subsection 13(1) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(1) recapture from rental property is property income from that property Before finding that there was no attribution of recapture of depreciation by virtue of the exception from the application of s. 74.1(1) contained in s. 74.5(3)(a), CRA stated, in its summary: [T]he nature of recapture of depreciation is analogous to the nature of the depreciation expense that was claimed in the past. ...

3 December 2013 TEI Roundtable, 2013-0510851C6- 2013 TEI – Question 9: Tax residency certificates.-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) no residency certificates for partnerships Would CRA be willing to issue Canadian tax residency certificates in the name of a Canadian partnership on the basis of the Canadian residency of all its partners? ...

25 April 2014 External T.I. 2013-0515621E5 F- Frais de voyage / Travelling expenses-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) benefit where employer pays costs of friend to accompany employee on training trip An employee, who must undergo training outside the country, is allowed to be accompanied by a friend (who has no connection to the employer’s business) whose travel expenses (accommodation, airfare and meals) are paid by the employer. ...

30 October 2012 Ontario CTF Roundtable Q. 8, 2012-0462841C6- Ontario CTF – Q8 Residency of a Trust-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) trust residence following Fundy In response to a query on the Fundy Settlement case, CRA stated: Normally, residence of a trust is dependent upon residence of the trustee or trustees who can exercise management and control of the trust. ...

11 October 2013 Internal T.I. 2013-0475761I7- Deadline for filing a waiver of tax credit – ORDTC-- summary under Subsection 152(4) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4) waiver of credit after return due date A corporation filed its original 2011 T2 return somewhat after the filing due date, and then requested an adjustment to amend the return by waiving the full amount of the previously-claimed Ontario Research and Development Tax Credit. ...

3 June 2014 External T.I. 2014-0518911E5 F- Grand routier / long-haul truck-- summary under Long-haul truck Summary Under Tax Topics- Income Tax Act- Section 67.1- Subsection 67.1(5)- Long-haul truck weight reference is to loaded weight determined by manufacturer Does the gross vehicle weight rating refer to the loaded capacity and does it include the weight of a trailer? ...

14 March 2013 Internal T.I. 2012-0451131I7- Trustee's Rights & Obligations under the Act-- summary under Subsection 150(3) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(3) Although s. 22 of the Bankruptcy and Insolvency Act requires a trustee to file only the return for the taxation year before the year of bankruptcy, and the return for the year of bankruptcy, s. 164(2.01) of the Act forbids the Minister from paying a refund where returns have not been filed under the Act. ...

29 April 2015 External T.I. 2014-0532691E5 F- Vente – immeuble- syndicat copropriétaire-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) distribution of gain to members of a condominium syndicate gave rise to a shareholder benefit After noting that a community of condominium owners is treated by s. 1039 of the Civil Code as a legal person, and is a corporation, CRA went on to indicate that when such a syndicate sold one of the condominiums at a capital gain and distributed the gain to its members then, as such members were deemed by the definition of “shareholder” in s. 248(1) to be shareholders, such distribution would give rise to a shareholder benefit. ...