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31 December 2015 External T.I. 2014-0556881E5- Bill C-43 – Calendar year for testamentary trusts CRA Tags 248(1) Principal Issues: Change in tax treatment of testamentary trusts arising from Bill C-43 may result in a deemed tax year end of December 31, 2015. ... King December 31, 2015 Dear XXXXXXXXXX: Re: Bill C-43 – Calendar year for testamentary trusts This is in reply to your email correspondence and our telephone conversations during which you asked if there is any transitional relief with respect to the legislative changes in Bill C-43 which require an existing testamentary trust, which will not be a graduated rate estate, to have a taxation year that coincides with the calendar year; commencing with a deemed taxation year of December 31, 2015. ...

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution CRA Tags 93(2) 93(2.01) Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to shares owned by a taxpayer in respect of which the taxpayer made a capital contribution consisting of shares of another foreign affiliate? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 7 – Subsection 93(2.01) substituted property rule and capital contributions Assume the following hypothetical facts: a) Canco owns all of the shares of each of FA1 and FA2. b) Canco capitalizes FA1 with $1,000 of equity. c) FA1 loans $1,000 to FA2 for use in its active business. d) A few years later, after having paid dividends of $50 to Canco, FA1 becomes a wholly-owned subsidiary of FA2 as a result of a contribution of capital by Canco of the shares of FA1 to FA2. ...

13 February 2017 Roundtable, 2017-0684491C6- CPA-BC & CRA Roundtable 2017 Principal Issues: Whether the CRA will re-introduce a dedicated phone line for tax professionals. ... CPA-BC & CRA Roundtable 2017 Question 16: We were very excited about the introduction of the CRA’s “professional designated phone line”, only to find out that this was meant for small practitioners who have no tax advisers. ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit Unedited CRA Tags 126 4 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. ... Other jurisprudence that supports the principle that a business is generally considered to be carried on in the place where the operations from which the profits arise are located and not necessarily where the sales contracts are made include: (a) F.L.Smidth & Co. v. ... (b) Firestone Tyre & Rubber Co., Ltd. V. Lewellin (HM Inspector of Taxes) (1957, 37 TC 111, at 142, "It follows then that the place of sale will not be the determining factor if there are other circumstances present that outweigh its importance or unless there are no other circumstances that can. ...

20 June 2007 Internal T.I. 2006-0178941I7- Foreign Spin-off & Foreign Merger Unedited CRA Tags 86.1(1) 87(8) 87(8.1) Principal Issues: 1. ... Newco shares were not listed under a symbol proper. • No information concerning the buying or selling transactions of Newco shares were provided. ... Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...

30 September 2013 Internal T.I. 2012-0439661I7- Income earmarked for future use & 95(2)(a)(i) CRA Tags 95(1) 95(2)(a)(i) Principal Issues: Whether the income earned by one foreign affiliate on property that is earmarked for future development of another foreign affiliate's active business can be included in income from active business under paragraph 95(2)(a). ... In other words, the property has to be an integral part of the financing of the business or necessary to the overall business operations in order for income from the property to be part of the income of the corporation … from an active business. ... MNR, 87 DTC 450 at 457; McCutcheon Farms, supra note 2 at 1214; Transport Lacte Inc, supra note 3 at 610; Muir Cap & Regalia Ltd v. ...

6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property CRA Tags 110.6(1) 95(1) 149(10) Principal Issues: Whether internally generated goodwill should be considered in the determination of the excluded property status of shares of a foreign affiliate held by another foreign affiliate? ... Truong: Internally Generated Goodwill & Excluded Property Status We are writing in response to your e-mail dated June 25, 2014 wherein you asked whether internally generated goodwill should be considered in determining whether shares of a foreign affiliate ("FA2") of a corporation resident in Canada qualify as "excluded property", as that term is defined in subsection 95(1) of the Income Tax Act (the "Act"), of another foreign affiliate ("FA1") of the corporation. ... Our comments The relevant part of the definition "excluded property" in subsection 95(1) reads as follows: "excluded property", at a particular time, of a foreign affiliate of a taxpayer means any property of the foreign affiliate that is (a) used or held by the foreign affiliate principally for the purpose of gaining or producing income from an active business carried on by it, (b) shares of the capital stock of another foreign affiliate of the taxpayer where all or substantially all of the fair market value of the property of the other foreign affiliate is attributable to property, of that other foreign affiliate, that is excluded property, […] Pursuant to paragraph (b) of that definition, the shares of FA2 will qualify as excluded property of FA1 if all or substantially all of the fair market value of FA2's property is attributable to property that is excluded property. ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C) CRA Tags 94(3) Principal Issues: Can a non-resident trust that is subject to "new" subsection 94(3) deduct an amount under subsection 91(5) in respect of a FAPI inclusion resulting from the application of "old" clause 94(1)(c)(i)(C)? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2015-059849 91(5) Deduction – Non-Resident Trust Subject to “Old” Clause 94(1)(c)(i)(C) This letter is in reply to correspondence received from XXXXXXXXXX, an International Tax Auditor with the XXXXXXXXXX Tax Services Office, on July 14, 2015, wherein she requested our assistance in respect of the possible application of subsection 91(5) to a particular situation involving a non-resident trust. ... Comments The relevant portions of “old” subparagraph 94(1)(c)(i) read as follows: (i) the trust is deemed for the purposes of this Part and sections 233.3 and 233.4 to be a person resident in Canada no part of whose taxable income is exempt because of section 149 from tax under this Part and whose taxable income for the year is the amount, if any, by which the total of (…) (C) the amount, if any, by which the total of all amounts each of which is an amount required by subsection 91(1) or (3) to be included in computing its income for the year exceeds the total of all amounts each of which is an amount deducted by it for that year under subsection 91(2), (4) or (5), and Based on the wording of “old” clause 94(1)(c)(i)(C), the FAPI-Inclusions consist of net amounts of inclusion resulting from the application of subsections 91(1) or (3), and subsections 91(2), (4) or (5), as the case may be, in computing NRT’s income for its 2002, 2004 and 2006 taxation years. ...

12 January 2022 Internal T.I. 2021-0920371I7- METC – Cost of a cast Unedited CRA Tags Section: 118.2; paragraphs 118.2(2)(i) and (m), paragraph (i) of Regulation 5700 Principal Issues: Whether the cost of a walking cast would qualify as an eligible medical expense for the purposes of the METC. ... January 12, 2022 Marie-Pier Valiquette Income Tax Rulings Directorate A/Senior Programs Officer, Business and Employment Division Sales Tax and Benefits Information Cynthia Underhill Section, ABSB 2021-092037 Medical expense tax credit – eligibility of a walking cast We are writing in response to your email dated December 8, 2021, asking if the cost of a walking cast would qualify as a medical expense for purposes of the medical expense tax credit (“METC”), under section 118.2 of the Income Tax Act (Act). ... Section 5700 of the Regulations states: “[Prescribed device or equipment] — For the purposes of paragraph 118.2(2)(m) of the Act, a device or equipment is prescribed if it is a... ...

26 July 2012 External T.I. 2011-0431681E5- Taxable Benefits – Recreational Facilities Unedited CRA Tags 6(1)(a) Principal Issues: 1. ... Baltkois July 26, 2012 Dear XXXXXXXXXX: Re: Taxable Benefits – Recreational Facilities We are writing in response to your fax dated December 8, 2011, in which you requested our comments as to whether an employee’s use of an employer provided in-house fitness centre would result in a taxable benefit. ...