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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). ...

17 June 2013 External T.I. 2013-0486901E5- Petroleum & Natural Gas Lease-- summary under F Summary Under Tax Topics- Income Tax Act- Section 66.4- Subsection 66.4(5)- F proceeds of CRP upon entering into oil and gas lease The taxpayer inherited subsurface exploration rights from his father with a deemed cost under s. 70(5.2) equal to their fair market value, and leased those rights to a corporation for a lump sum. ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4-- summary under Subsection 20(11) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(11) Art. ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Art. 24(5) of US treaty a complete code for US citizens A U.S. citizen is required to pay U.S. tax on dividends and capital gains at a 20% rate (increased from the previous 15% rate). ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Subsection 70(5) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(5) The questioner referenced the CRA statement at the 2009 British Columbia Tax Conference that, in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of the estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, CRA generally accepts that no premium should be attributed to such shares in determining their fair market value under s. 70(5), and asked whether this position also applies for the purposes of s. 104(4)(a), e.g., re the deemed disposition arising on the death of the spouse who is the beneficiary of a spousal trust. ...

13 February 2013 External T.I. 2011-0430921E5 F- S. 261- Loss carry-back & loss carry-forward-- summary under Subsection 261(12) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(12) conversion to U.S. dollar and back again changed non-capital losses The taxpayer elected in its December 31, 2009 taxation year to adopt the U.S. dollar as its functional currency in accordance with s. 261(2), and revoked that election in its December 31, 2011 taxation year in accordance with s. 261(4). ...