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18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(5) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(5) building shell was a building or structure/ addition refers to extension of structure The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ...

10 October 2024 APFF Roundtable Q. 2, 2024-1028371C6- Transfert intergénérationnel d’entreprise – nouvelles règles-- summary under Paragraph 84.1(2.32)(a) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(a) s. 84.1(2)(e) exception is available only for the 1st disposition if the subject corporation shares are sold in tranches A parent wishes to access the s. 84.1(2.31) or (2.32) rules regarding a transfer of the shares of Parent Inc. ...

2013 Ruling 2012-0467721R3- IV(7)(b) & PUC increase-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 two-step distribution to two S-Corp shareholders of ULC/interest payment to one USCo and USCo2 are each S Corporations whose shares are owned in the same proportions by U.S. ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Paragraph 5907(1.3)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1.3)- Paragraph 5907(1.3)(a) overview of FAT rules re consolidated US return with R&D credit Four U.S. ...

10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 5, 2024-1023291C6 F- Paiements rétroactifs- Droits ou biens / Retroact-- summary under Subsection 70(2) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(2) s. 70(2) return can be filed before the filing deadline with an estimated amount if precise amount is not yet known due to administrative delay A taxpayer died in October 2021 after a pay equity settlement was reached with the Quebec government in June 2021. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Paragraph 95(2)(c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(c) rollover is available on joint drop-down of shares of a Dutch private limited liability company into a Dutch cooperative in consideration for respective credits to the membership accounts Current structure Forco 1 is held through three stacked Canadian partnerships by two taxable Canadian corporations (Canco 1D and Canco 1A) which, in turn, are indirect wholly-owned subsidiaries of a non-resident parent (“Parent”). ...

. … … 2019-0799901C6 … and … Example 9 of … Guidance on the Application of the Split Income Rules for Adults provide useful general guidance …. In particular … 2019-0799901C6 … indicated that a husband and wife could both be considered to be actively engaged in the activities of a particular business carried on by their corporation on a regular, continuous and substantial basis for a particular year where the particular business did not require any other workers and only required them to spend on average 5 hours each per week in that business. ...

The mid-amble of subsection 13(29) … clearly indicates that the taxpayer must file a single election with its return for the “particular year” …. Once the Long-Term Project election has been filed with its return for the particular year, subsection 13(29) will apply in respect of the taxpayer’s “inclusion year” … [which g]enerally … will be the third and subsequent taxation years of the project where the taxpayer owns project property in that taxation year that has not yet otherwise become available for use. … … The … current … Form T1031 suggests that the form must be filed annually. … Form T1031 is currently under review. ...

The Directorate responded: [S]ubsection 246(1) is generally a provision of subsidiary application since it must be shown that the value of the benefit is not otherwise included (for example, by virtue of paragraph 6(1)(a) or subsection 15(1)) in computing the taxpayer's income …. On the other hand … Massicotte … held that the Minister of National Revenue may assess a taxpayer solely on the basis of section 246 despite the fact that paragraph 6(1)(a) could have been argued …. … Thus, while the Minister may invoke subsection 246(1) as the sole ground for assessment, we believe it is preferable that the assessment refer- if the facts of the situation are appropriate- to the provisions of specific application. … [T]herefore … the assessment should rely on paragraph 6(1)(a) and/or subsection 15(1) as the main grounds …. ...

For example: The RestaurantCo certificate offers discounts at […] locations in […] [Participating Province X]. ... The certificate has a value of over $[…] and is sold for $19.99. It has four components: A single use [dining] offer of a […]% discount on food total (maximum value $[…]) […] free dinner entrees: Buy one, get one […] free lunch entrees: Buy one, get one Purchaser will receive $[…] in RestaurantCo cash with every catered order over $[…] CRA rules that the certificates are not gift certificates for GST purposes, as they do not have a monetary value. ...