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Technical Interpretation - External summary
11 October 2017 External T.I. 2016-0673171E5 - Foreign tax credit - former resident -- summary under Subsection 126(2.21)
CRA responded: [P]ursuant to subparagraph 152(4)(b)(i), paragraph 152(6)(f.1) and subsection 152(4.01) … an assessment to take into account a foreign tax credit under subsection 126(2.21) of the Act in respect of foreign taxes paid is permitted only where the assessment is made within 3 years after the normal reassessment period. ... …The Minister is not obligated to reassess a return simply because a waiver is filed by a taxpayer for a particular taxation year …. [A] blanket waiver request without sufficient details of a transaction would likely not be considered valid. … … 2016-066042 … opined that if any of the circumstances to support the deduction under subsection 126(2.21) of the Act (e.g., disposition of the property and/or foreign taxes paid) are present within the statutory assessment period referred to in paragraph 152(4)(b) of the Act, it may be appropriate for the Minister to consider a taxpayer’s waiver request for the emigration year to allow the Minister sufficient time to review and process any potential reassessment for this deduction beyond the aforementioned reassessment period. ...
Technical Interpretation - External summary
27 May 2010 External T.I. 2010-0359491E5 F - Programme Agri-investissement -- summary under Subsection 12(10.2)
The second fund is … a "NISA Fund No. 2 " …. Generally, a taxpayer must include in computing income for a taxation year from property by virtue of subsection 12(10.2) the total of all amounts paid to the taxpayer from the taxpayer's NISA Fund No. 2. ...
Technical Interpretation - External summary
20 March 2025 External T.I. 2024-1042821E5 - Application of 237.5 - RUTT disclosure -- summary under Reportable Uncertain Tax Treatment
CRA indicated that: “based on the context in which the RUTT regime was introduced … the definition of a RUTT should be interpreted broadly. ... The CRA Guidance stated that uncertainty is reflected in the financial statements, for example, if “the entity concluded it is not probable that the tax authority will accept an uncertain tax treatment and thus … it is probable that the entity will receive or pay amounts relating to the uncertain tax treatment ….” ... When that is the case, the RUTTs must be disclosed in Form RC3133 …. … [T]he notes to the audited financial statements prepared in accordance with … IFRS … or any other country-specific generally accepted accounting principles need to be considered when determining whether the uncertainty of tax treatments is reflected in the relevant financial statements …. ...
Technical Interpretation - Internal summary
9 April 2003 Internal T.I. 2003-0001597 F - FRAIS ACCESSOIRES -- summary under Subsection 18(3.1)
9 April 2003 Internal T.I. 2003-0001597 F- FRAIS ACCESSOIRES-- summary under Subsection 18(3.1) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(3.1) application of s. 18(3.1) to work on a rental property The Directorate indicated that s. 18(3.1) applied to the following categories of expenditures if work on a rental building constituted a renovation rather than repair and maintenance work giving rise to currently deductible expenses: Property taxes during the renovation period that are related to the ownership of the land subjacent to the building …. … [P]roperty taxes related to the ownership of land that meets the following conditions: 1. it is contiguous to the land subjacent to the building 2. it is used, or intended to be used, as a parking lot, driveway, yard or garden or for a similar purpose 3. it is necessary for the present or proposed use of the building. … Interest charges on the portion of the mortgage obtained to renovate the building that relates to the renovation period … [and] interest charges on the portion of the mortgage used to acquire the land described above that relates to the renovation period. Insurance and utility costs … only to the extent that they relate to the renovation. For example, this would be the case for additional insurance costs that the taxpayer had to incur to cover a risk related to the renovation. … Legal costs related to obtaining financing for the renovation … [and] the legal costs of acquiring the building and land …. ...
Technical Interpretation - External summary
3 August 2004 External T.I. 2004-0066431E5 F - Contrat de rente et fiducie -- summary under Subsection 75(2)
This interpretation is consistent with [9422630] …. Since … the trust indenture indicates that the trustees shall act in a manner that promotes or supports the purposes for which the trust was created, the granting of annuity contracts by the trust is part of a strategy to increase its gift income and enable it to achieve its purposes, even though the trust indenture contains no specific reference to the provision of such annuity contracts. … [T]herefore … subsection 75(2) applies …. ...
Technical Interpretation - External summary
31 July 2013 External T.I. 2012-0452591E5 F - Matériel lié à un programme d'études -- summary under Paragraph 56(3.1)(b)
CRA responded: As described in … S1-F2-C3 … 3.94 … materials related to the program includes the cost of items that are essential for the completion of the program and are expected to have a lifespan use generally limited to the program length, such as books, lab coats, brushes and paints. ...
Technical Interpretation - External summary
30 November 2004 External T.I. 2004-0090181E5 F - Assurance maladie grave -- summary under Paragraph 18(1)(h)
Furthermore, where the corporation is the beneficiary of a policy acquired to finance a share purchase/redemption under a shareholders' agreement … the premiums are not made or incurred for the purpose of earning business income as required by paragraph 18(1)(a) or paragraph 18(1)(h). ... If a critical illness policy were used as collateral for a corporate loan, the premiums would also be non-deductible …. Antoine Guertin …. … Premiums paid by the corporation for the rider to the policy allowing it to obtain a premium refund amount if the shareholder does not have one of the covered illnesses or medical conditions after 10 years are not deductible on the basis of the application of paragraphs 18(1)(a) and 18(1)(h). ...
Technical Interpretation - External summary
27 March 2014 External T.I. 2014-0524851E5 F - Deemed year-end and CPCC status -- summary under Subsection 249(3.1)
That is what the Tax Court of Canada indicated in … Ekamant … 2009 TCC 408 …. Thus … Corporation A did not become a CCPC at the time of the signing of the purchase offer made by Corporation B since it continued to be controlled by Pubco at that time. ...
Technical Interpretation - External summary
2 November 2009 External T.I. 2009-0317541E5 F - Transfer to Corporations Owned by Brothers -- summary under Subparagraph 55(5)(e)(ii)
A, Holdco A and Trust A sell ½. ½ and ¼, respectively, of their shares of Corporation A on a s. 85(1) rollover basis in exchange for similar-attribute shares of Newco. ...
Technical Interpretation - External summary
13 June 2012 External T.I. 2011-0416781E5 F - Entente contractuelle particulière -- summary under Subparagraph 20(1)(c)(i)
. … … [I]t cannot be considered … that the amounts payable by Corporation B and/or Corporation C under the second contract could represent consideration for the use of an amount of capital (or a right to the amount of capital). … [In addition t]he contractual relationship between Corporation A and Corporation B, on the one hand, and Corporation A and Corporation C, on the other hand, … does not appear to us to create a lender-borrower relationship between those corporations, so that subparagraph 20(1)(c)(i) cannot be applicable. ...