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13 February 2013 External T.I. 2011-0430921E5 F- S. 261- Loss carry-back & loss carry-forward-- summary under Subsection 261(15) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(15) carryback of non-capital loss following revocation of functional currency election to functional currency year 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). ...

22 October 2013 External T.I. 2013-0503311E5- Class. of steel tanks & oak barrel for CCA purpose-- summary under Class 29 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 29 A CCPC wine producer whose activities include growing and purchasing, and then pressing, grapes, fermenting and aging wine, and bottling and corking or capping for distribution, owns steel tanks and oak barrels, which it acquired after March 18, 2007 and are used in fermenting and aging the wines before they are sold by it. ...

4 December 2013 External T.I. 2012-0465891E5 F- Primes d'assurance / Premiums-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) insurance premium benefits qua shareholder When asked whether there would be a taxable benefit where Corporation A, which had other insured employees as well, paid insurance premiums for life insurance policies and disability policies covering Mr. ...

10 February 2015 External T.I. 2014-0549331E5 F- Borne de recharge – catégorie d'amortissement-- summary under Class 43.2 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 43.2 vehicle charging stations included in Class 8, not 43.1 or 43.2 An employer acquired charging stations, which were used only to recharge the employer's electric vehicles that were used by its employees for travel to customers. ...

3 March 2015 External T.I. 2014-0519981E5 F- Donation avec charge / Gift with a charge-- summary under Paragraph 69(1)(b) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) gift of encumbered property An individual donates a real estate property with a fair market value of $200,000 that is charged with a hypothec of $100,000. ...

4 March 2015 External T.I. 2014-0562151E5 F- Frais de psychothérapie – dépense d'entreprise-- summary under Subsection 248(28) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(28) potential choice between claiming therapy expense and credit After finding that psychotherapy expenses potentially could be deducted in computing income of a professional practice, CRA stated: The fact that psychotherapy fees could give rise to a credit under the Act does not preclude their deduction in the computation of income from your business. ...

2013 Ruling 2013-0475701R3- MIC deemed interest & participating debt interest-- summary under Participating debt interest Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(3)- Participating debt interest applies to dividends deemed to be interest The Corporation, a "mortgage investment corporation" under s. 130.1(6), pays dividends which take into account, inter alia, its income and financial conditions. ...

17 December 2013 External T.I. 2013-0510371E5 F- MCIA / CEC-- summary under Subsection 24(1) Summary Under Tax Topics- Income Tax Act- Section 24- Subsection 24(1) fmv reduction of eligible capital property to nil does not trigger loss if business still carried on A taxpayer acquired franchise rights which subsequently became worthless as a result of the bankruptcy of the franchisor. ...

4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9)-- summary under Subsection 116(1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(1) personal-use land and building are one property A U.S. resident owned vacant land in Canada from before September 26, 1980 and after that date built a cottage thereon. ...

4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 personal-use land and building are one property A U.S. resident owned vacant land in Canada from before September 26, 1980 and after that date built a cottage thereon. ...