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21 November 2014 External T.I. 2014-0536771E5 F- Supplément pour frais médicaux – Revenu modifié-- summary under Cohabiting Spouse or Common-Law Partner Summary Under Tax Topics- Income Tax Act- Section 122.6- Cohabiting Spouse or Common-Law Partner surviving spouse is not living separate and apart from deceased spouse at year end Where a "cohabiting spouse or common-law partner" dies during a taxation year, is the income of the deceased spouse included in the computation of the refundable medical expense supplement ("RMES") of the surviving spouse; and is the surviving spouse's income included in the calculation of the RMES in the terminal return of the deceased spouse? ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Subparagraph 39(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(a)- Subparagraph 39(1)(a)(ii) CRA noted that an employer's group disability plan which was administered by an administrator (such as an insurance corporation) on an administrativee services only basis nonetheless would qualify as an insurance plan ("IP") (and a wage loss replacement plan ("WLRP")) for the purpose of paragraph 6(1)(f) of the Act, if it contained "an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) CRA noted that an employer's group disability plan which was administered by an administrator (such as an insurance corporation) on an administrativee services only basis nonetheless would qualify as an insurance plan ("IP") (and a wage loss replacement plan ("WLRP")) for the purpose of paragraph 6(1)(f) of the Act, if it contained "an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

18 October 2012 External T.I. 2012-0436181E5- Part IV Tax / Denied Dividend Refund-- summary under Subsection 129(1) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1) no requirement that "refund" be received There is a cross-redemption of preferred shares held by two connected corporations (Aco and Bco) in each other, thereby giving rise to Part IV tax based on their respective dividend refunds (which, in these circumstances, are generally determined on a circular basis). ...

12 June 2012 June STEP Roundtable, 2012-0442681C6- STEP CRA Roundtable – June 2012- Question 2-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) In response to a question as to whether a s. 160 would a apply to a butterfly reorganization (which typically entailed two share redemptions giving rise to deemed dividends), where the reorganization was intended to divide family assets between spouses in a divorce situation, CRA stated: [I]t would be a question of fact as to whether subsection 160(1) would apply to any of the transfers of property that would form part of the transactions involved in the reorganization. ...

6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property-- summary under Excluded Property Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Excluded Property unpurchased goodwill is taken into account Is internally generated goodwill considered in determining whether shares of a foreign affiliate ("FA2") of a corporation resident in Canada qualify as "excluded property" of another foreign affiliate ("FA1") of the corporation? ...

29 April 2015 External T.I. 2014-0532691E5 F- Vente – immeuble- syndicat copropriétaire-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) a syndicate of condominium co-owners could qualify as a s. 149(1)(l) corporation, so that a capital gain realized by it on a condo sale would be exempt A syndicate of co-owners holding condominium units sold one of the condominiums at a capital gain. ...

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves-- summary under Subsection 110.6(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(2) In response to a question "as to whether a taxpayer whose farm property meets the definition as a "qualified farm property" ("QFP") within the meaning of subsection 110.6(1)...will be eligible to claim the capital gains deduction under subsection 110.6(2) on a subsequent disposition of the farm property in circumstances where petroleum or natural gas reserves are discovered on the property," CRA responded: any real property the principal value of which depends on its petroleum, natural gas or related hydrocarbon content will constitute a "Canadian resource property" as defined in subsection 66(15) of the Act by virtue of paragraph (c) of that definition. ...

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves-- summary under Canadian Resource Property Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Canadian Resource Property In response to a question "as to whether a taxpayer whose farm property meets the definition as a "qualified farm property"... within the meaning of subsection 110.6(1)...will be eligible to claim the capital gains deduction under subsection 110.6(2) on a subsequent disposition of the farm property in circumstances where petroleum or natural gas reserves are discovered on the property," CRA responded: any real property the principal value of which depends on its petroleum, natural gas or related hydrocarbon content will constitute a "Canadian resource property"....For these purposes "principal" means more than 50%. ...

12 March 2015 External T.I. 2014-0541991E5- Objection – Eligible Dividend Designation-- summary under Subsection 89(14.1) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(14.1) designation conditional on appeal result: not acceptable A Canadian-controlled private corporation ("Canco") declared and paid out a dividend at a time it had an insufficient GRIP balance to make an eligible dividend designation. ...