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2010 Ruling 2010-0374141R3- Stock dividend from CFA & PUC Unedited CRA Tags 15(1); 15(1.1); 52(3); 53(2)(b)(ii); 84(4.2); 89(1); 95(7); 245(2); 248(1); 258(3); 258(5) Principal Issues: 1. ... Following the transactions described in paragraph 25 of this ruling letter, approximately XXXXXXXXXX % of Forco2's shares are owned by Forco1, while the remaining XXXXXXXXXX % are owned by XXXXXXXXXX. ... All of the Ordinary Shares have been issued to and owned by Canco continuously since their issuance and Canco has owned XXXXXXXXXX % of the issued and outstanding shares of Forco1 since the latter's formation. 29. ...

1997 Administrative Letter 971152B-: Tax Shelter- Prescribed Benefits & Revenue Guarantees Unedited CRA Tags: 237.1(1), ITR 231(6.1)(b)(ii), 143.2, 96(2.2)(d) Principal Issues: 1. ... Position: 1 & 2. Not as of the date of the ruling, based on certain provisos. 3 to 7. ... Reasons: 1 & 2. The statements and representations provided in Schedules "A" & "B" do not indicate that the interest in the Partnership would be a tax shelter and the statements and representations in Schedule "B" replace those in Schedule "A" and do not indicate that the Partnership's interest in XXXXXXXXXX would be a tax shelter. ...

28 March 1990 Income Tax Severed Letter AC74599- Recent Issues — OECD Working Party No. 6 Unedited CRA Tags none March 28, 1990 Provincial & International Specialty Rulings Relations Division Directorate H.K. ... Example A.1- Domestic merger where the acquired corporation has a p/e in another country (See paragraphs 13 to 15 of the Note) Scenario This scenario deals with two corporations (ACo & BCo) both of which are resident in Country X. ...

18 July 2012 Internal T.I. 2012-0440681I7- Distributions from deemed RCA; withhold & report CRA Tags 153(1)(q) 207.6(5) (5.1) Principal Issues: Is the custodian of a foreign pension plan, part of which is a residents' arrangement deemed to be an RCA under the Act, required to file T4A-RCAs when paying distributions out of the deemed RCA? ... This is consistent with the information provided in T4041 – Retirement Compensation Arrangements Guide, which indicates, at page 15, that a “custodian who makes a distribution out of an RCA trust has to file a T4A-RCA information return”. ... As previously indicated, it is only the portion of the Plan which is comprised of resident’s contributions – Employer’s contributions made during the XXXXXXXXXX calendar years with respect to the Canadian Employees – and property derived from those contributions that is deemed to be an RCA. ...

Our Comments 95(2)(b) & 247(2) With respect to the first issue, we are of the view that paragraph 95(2)(b) applies in respect of the R&D Services provided to Canco, notwithstanding that these services have been rendered under terms and conditions aligned with the arm’s length principle applicable for purposes of subsection 247(2). ... Exceptions of 95(3)(b) & (d) Regarding the second issue mentioned above, although we haven’t reviewed the relevant legal documentation that governs the interaction of the parties, we are of the view that no exception in paragraphs 95(3)(b) or (d) applies to allow the R&D Services provided to Canco not to be considered “services” for the purposes of paragraph 95(2)(b). ... Concerning the scope of paragraph 95(3)(b), it has been our longstanding position that the phrase “services performed in connection with the (...) sale of goods” is limited to services that are directly related to the sales function (in this respect, see for example documents 9729770, 2002-0123755 and 2013-0497361I7). ...

5 April 2018 Internal T.I. 2017-0728581I7- Ss 125(3.2) & 125(8) amending the business limit Unedited CRA Tags 125(1), 125(2), 125(3), 125(3.2) Principal Issues: Whether corporations can amend the assignment of the business limit under subsection 125(3.2) and the assignment of the specified partnership business limit under subsection 125(8). ... Godson 2017-072858 Subsection 125(3.2) and 125(8) – amending an assignment of the business limit We are writing in reply to your enquiry of October 20, 2017, requesting our response to questions from the CPA forum – Saskatchewan. ... Will this administrative position continue to apply with respect to an amended assignment of a partner’s specified partnership business limit / an amended assignment of the business limit by the “first corporation” to a “second corporation” that earned specified corporate income from the first corporation? ...

18 September 1995 External T.I. 9507235- LOAN OF MONEY-17(1) & GUARANTEE V. ... II.Legislation & jurisprudence (SEE A.C.Simmonds 89 DTC 707) 950723 XXXXXXXXXX G. ... Yours truly, Chief Financial Institutions Section Financial Industries Division Income Tax Rulings and Interpretations Directorate Policy & Legislation Branch ...

Question 4 – “Common share” What is a “common share” and what is not? ... Question 6 – “Publicly traded company” What is a “publicly traded company”? ... Question 7 – “Subsidiary” What constitutes a “subsidiary”? a. Is the standard based on voting control? ...

23 January 2023 External T.I. 2020-0842761E5- METC – Amounts paid for attendant care Unedited CRA Tags ITA: Subsection 118.2(2); 118.3(1); Paragraphs 118.2(2)(b), (b.1), (b.2), (c), (d), and (e); and 118.3(1)(c). ... Underhill January 23, 2023 Dear XXXXXXXXXX: Re: Medical Expense Tax Credit – remuneration paid for attendant care We are writing in response to your correspondence asking if an individual who resides in a retirement home may claim amounts paid as remuneration for attendant care (full or part-time), under various scenarios, as an eligible medical expense for the purposes of the medical expense tax credit (METC). ... In your submission, you referred to Lines 33099 and 33199 – Eligible medical expenses you can claim on your tax return on the Canada Revenue Agency’s (CRA) website and Guide RC4065, Medical Expenses. ...

Income Inclusion – Overview Pursuant to the Act, a taxpayer, who is resident of Canada, is subject to income tax on all items of revenue received from all sources inside or outside of Canada. ... CCA – Overview A taxpayer may claim CCA only on property described in Schedule II of the Regulations that was acquired for the purpose of earning income. ... Specified Energy Property Rules – Overview The specified energy property rules contained in subsections 1100(24) to (29) of the Regulations limit the amount of CCA that may be claimed on property that is “specified energy property.” ...