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21 January 2009 External T.I. 2008-0266191E5 F- Part IV & Capital Gain Strip-- summary under Paragraph 186(1)(b) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1)- Paragraph 186(1)(b) 943963 Ontario followed CRA confirmed its position in 9711005 and indicated that its position in 9906255 was no longer valid because of the 943963 Ontario decision. ...

16 May 2018 IFA Roundtable Q. 9, 2018-0748151C6- T1134s & Country by Country Reporting-- summary under Subsection 233.4(4) Summary Under Tax Topics- Income Tax Act- Section 233.4- Subsection 233.4(4) comparison of T1134 and CbC reporting Although the mandated requirement is a Finance requirement, what is CRA’s perspective on whether there is a need for T1134 filing in addition to the mandated country-by-country reporting? ...

17 March 1997 Internal T.I. 9631007- INTERACTION OF 85(1) & 110.6(19)-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) The benefit of making an election under s. 110.6(19) in respect of an eligible capital property or a depreciable property effectively will be lost if the property is transferred on a rollover basis to a corporation. ...

20 October 1997 External T.I. 9715265- INTERACTION OF SUBSECTION 212(11) & PARAGRAPH 212(1)(C)-- summary under Subsection 212(11) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(11) "In our view, subsection 212(11) of the Act merely characterizes any amount paid or credited by a trust or estate as income of the trust or estate for the purposes of paragraph 212(1)(c) of the Act. ...

13 May 1998 External T.I. 9718325- 104(13.1) & 104(18)-- summary under Subsection 104(13.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13.1) "Subsection 104(13.1) permits a trust to deduct less than the full amount of its income payable to a beneficiary and thus choose to have that income taxed at the trust level rather than the beneficiary level.... ...

14 July 1994 Internal T.I. 9407377- NON-RESIDENT PARTNER & 216 ELECTION (7558-3)-- summary under Regulation 805 Summary Under Tax Topics- Income Tax Regulations- Regulation 805 If a partnership is determined to be carrying on business in Canada, there will be no Part XIII tax liability in respect of rent paid to the partnership on the presumption that a non-resident partner is considered to be carrying on business through a permanent establishment in Canada. ...

1 September 1994 External T.I. 9413775- ELIGIBLE PROPERTY & CUM DIVIDENDS-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property right to accrued dividends is not separate property from the shares In finding that the right to accrued but undeclared dividends was not a separate eligible property from the preferred shares on which they had accrued, Revenue Canada stated: The right to accrued cumulative dividends would be just one of the bundle of rights that would be attached to a particular share.... ...

30 June 1994 External T.I. 9412365- PREFERRED BENEFICIARY ELECTION & CAPITAL GAINS-- summary under Subsection 2800(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 2800- Subsection 2800(3) Respecting a situation in which the beneficiaries of a trust established by a father were the grandchildren, children and the mother, and income could be distributed at the discretion of the trustees to the mother, the children or the grandchildren in amounts decided by the trustees, RC noted that where Regulation 2800(3)(e) applies, the discretionary share of the spouse (i.e., mother) is 100% of the accumulating income (which would include taxable capital gains) regardless of the fact that there are other income and capital beneficiaries, and that she is not a capital beneficiary. ...

30 January 1995 External T.I. 9430685- RRSP QUALIFIED INVESTMENTS- PUTS & CALLS-- summary under Subsection 146(10) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(10) Where cash is deposited as margin with a broker then, notwithstanding that such deposit would not be a qualified investment under s. 204(e)(i), s. 146(10) will not be applied to the annuitant if the transaction is concluded within a few days. ...

Dad invests $ in "trust" a/c for KIDS-- summary under Subsection 74.1(2) Summary Under Tax Topics- Income Tax Act- Section 74.1- Subsection 74.1(2) The word "transfer" means to "divest, deprive or dispossess of title". ...