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22 October 1993 Income Tax Severed Letter 932308- PHSP & Same Sex Issue Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

26 June 2024 External T.I. 2023-0961541E5- Retiring allowance – instalment payments Unedited CRA Tags 248(1) definition "retiring allowance"; "superannuation or pension benefit"; 56(1)(a)(ii) Principal Issues: Whether a retiring allowance that is paid in instalments is required to be paid within a certain period of time after termination of employment? ...

20 June 2006 External T.I. 2005-0149651E5 F- CEE / FEC Unedited CRA Tags 66.1(6) Principal Issues: In a given situation, where the exploration of a mining site starts up XXXXXXXXXX and costs must be incurred to make the site safe for the employees before further exploration can proceed, whether the costs related to making the site safe qualify as CEE? ... La situation Votre société a entrepris récemment des travaux préliminaires d'exploration à l'égard d'une "ressource minérale ", au sens prévu au paragraphe 248(1), sur une propriété minière située au Canada (ci-après la "Propriété") XXXXXXXXXX. ...

19 December 2006 External T.I. 2006-0189491E5- Revised carryback & Interest computations Unedited CRA Tags 161(1) 161(7) 152(6) 111 Principal Issues: Where in year 3 by virtue of ss.152(6), the taxpayer requests a reduction of tax for year 1 by means of a loss carryback from year 3 to year 1, but then subsequently in year 5, revises the request in order to increase the loss carryback from year 3 to year 1, would the interest charged pursuant to subsections 161(1) and (7) be charged on the combined reduction up to the date of the later request, or would interest be charged on each reduction separately up to the date of each respective request? ... In respect of Scenario A, you seem to be concerned that the subsequent request for loss carryback made in year 5 may reset the interest calculation date under paragraph 161(7)(b) for the total tax reduction resulting from all amounts carried back (i.e., $500 + $500) from year 3 to year 1 so that interest is payable on the entire $400 of reduction of tax payable for the period from the balance-due day of year 1 to the day that is 30 days after the day in which the latest carry back request was made in year 5, pursuant to subparagraph 161(7)(b)(iv). ...

2005 Ruling 2004-0096171R3- Treaty Benefits & Carrying Business in Canada Unedited CRA Tags 2(3) Principal Issues: 1) Whether the US corporation will be entitled to the benefits of the treaty notwithstanding the proposed transaction? ... For XXXXXXXXXX, approximately XXXXXXXXXX % of THE GROUP "Americas" revenue was from Canadian customers. ...

26 May 1998 Internal T.I. 9733167- INTEREST CHARGES ON AMENDED RETURNS / LOSSES Unedited CRA Tags 161(7)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Thus when the amended return was filed it was merely a matter of substituting one type of loss for another — the taxable income remained nil. ...

8 September 1994 Internal T.I. 9420937- HUSBAND & WIFE PARTNERSHIP Unedited CRA Tags 96 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... September 8, 1994 XXXXXXXXXX District Office Head Office Audit Adjustments & Enquiry Rulings Directorate C. ...

19 September 2003 External T.I. 2003-0034095- Specified bene of trust & change prin res Also released under document number 2003-00340950. ... Murphy Section Manager for Division Director International & Trusts Division Income Tax Rulings Directorate Policy and Legislation Branch- 4- ...

23 March 2021 TEI Roundtable, 2021-0879631C6- CERS- Net Leases, Qualifying Revenue & Deadlines Unedited CRA Tags 125.7 PRINCIPAL ISSUES: 1- Various questions on the eligibility of utilities expenses for the CERS 2- Does an eligible entity have to compute its qualifying revenue using the same approaches and elections for both the CEWS and the CERS for a particular qualifying period? ... REASONS: 1- Wording of the Act 2- Wording of the Act 3- Wording of the Act TEI 71st Virtual Midyear Conference – March 22 to 25, 2021 CRA Roundtable Question 1- CERS and Net Leases The Canada Revenue Agency has received a number of questions from taxpayers and their representatives about qualifying rent expenses and, in particular, whether utilities paid by a tenant may be claimed under the Canada Emergency Rent Subsidy (or “CERS”). ...

26 October 2021 Internal T.I. 2021-0892731I7- METC – Renovation expenses Unedited CRA Tags Sections 118.2; 118.3; and 118.041; ss 118.4(2); paragraph 118.2(2)(l.2) Principal Issues: Whether the costs incurred to modify an existing deck qualify as a medical expense for purposes of the METC. ... The terms qualifying individual, eligible individual, qualifying expenditure, qualifying renovation, and eligible dwelling are all defined in section 118.041 of the Act and explained on the CRA webpage, titled “Line 31285 – Home accessibility expenses” at canada.ca/line-31285. ...