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2013 Ruling 2013-0488661R3- Indian Band-Public Body & Function of Government CRA Tags 149(1)(c) Principal Issues: Is the XXXXXXXXXX a public body performing a function of government within the meaning of 149(1)(c) and therefore exempt from income tax on the interest income received from a GIC? ... XXXXXXXXXX 2013-048866 XXXXXXXXXX, 2013 Dear XXXXXXXXXX: Re: Advance Income Tax Ruling Request – XXXXXXXXXX This is in reply to your letter of XXXXXXXXXX, in which you requested an advance income tax ruling on behalf of the above-named taxpayer. ...

30 October 2012 Ontario CTF Roundtable Q. 8, 2012-0462841C6- Ontario CTF – Q8 Residency of a Trust Principal Issues: Impact on the CRA published position in relation to the factors it considers indicative for purposes of establishing residency of a trust in light of the 2012 SCC decision in St. ... Reasons: Comments as previously published by the Directorate at the Prairie conference and the BC conference Ontario Tax Conference October 30, 2012 Question 8 – Residency of a Trust for Tax Purposes (a) CRA's long-standing position on the determination of the residency of a trust for tax purposes is described in IT-447 Residence of a Trust or Estate (published in 1980). ...

12 March 2015 External T.I. 2014-0541991E5- Objection – Eligible Dividend Designation Principal Issues: 1. ... Ng (416) 512-4013 March 12, 2015 Dear XXXXXXXXXX, Re: Objection – Eligible Dividend Designation We are replying to your letter of August 1, 2014 in which you requested our comments with respect to the manner in which a taxpayer can make a late eligible dividend designation in the event that an assessment by the Canada Revenue Agency (the "CRA") which causes the taxpayer's general rate income pool ("GRIP") balance to increase is upheld at the end of the appeals process. ...

8 May 2012 Roundtable, 2012-0435641C6- CALU CRA Roundtable Question 6 – May 2012 Unedited CRA Tags 104(1), 89(1)(d) Principal Issues: Whether a corporation can be considered to have received insurance proceeds for the purpose of paragraph (d) in the definition of "capital dividend account" in subsection 89(1)? ... Question 6 – Use of Bare Trustee and CDA Background It is not uncommon for shareholders of a corporation to use a buy-sell arrangement which requires the corporation to acquire insurance to fund share purchase obligations under the arrangement. ...

21 November 2005 External T.I. 2005-0143231E5- Terminal Charge / ONT Tax Reduction Unedited CRA Tags 6(2) Principal Issues: (a) The taxable status of a $XXXXXXXXXX terminal loss incurred by an employer in respect of a leased automobile at the end of the lease- should the entire amount of the terminal loss be included in the employee's income as a taxable benefit? ... Randy Hewlett XXXXXXXXXX 613-957-2049 2005-014323 November 21, 2005 Dear XXXXXXXXXX: Re: Automobile Benefit / Ontario Tax Reduction We are writing in response to your letter of April 30, 2005, which was sent to the CRA's Summerside Taxation Center. ...

7 October 2002 Internal T.I. 2002-0159947- MEALS & ENTERTAINMENT EXPENSES Unedited CRA Tags 67.1(2)(a) 67.1(2)(e) 67.1(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Seidel, CMA (613) 957-2058 October 7, 2002 Dear XXXXXXXXXX: Re: Meals & Entertainment Expenses This is in reply to your letter dated August 22, 2002, in which you requested our views concerning the deductibility of certain meal and entertainment expenses and the application of subsection 67.1(1) of the Income Tax Act (the "Act") to such expenses. ...

29 October 2020 External T.I. 2020-0835681E5- Indian Act Exemption – Employment Income Unedited CRA Tags 81(1)(a); Indian Act s.87 Principal Issues: Are the employees (those working at the field office and those doing XXXXXXXXXX) exempt from income tax pursuant to Guideline 2? ... Gauthier October 29, 2020 Dear XXXXXXXXXX: Re: Indian Act Exemption for Employment – Guideline 2 This is in reply to your email dated January 7, 2020 where you asked whether employees of a partnership would be exempt from tax pursuant to Guideline 2 of the Indian Act Exemption for Employment Income Guidelines. ...

6 March 2023 External T.I. 2023-0960671E5- Carriage house & multigenerational home renos Unedited CRA Tags The definition of "qualifying renovation" and "secondary unit" in subsections 122.92(1). ... El-Kadi March 6, 2023 Dear XXXXXXXXXX: Re: Multigenerational home renovation tax credit – building a carriage house as secondary unit We are writing in response to your email of January 12, 2023, in which you asked whether the multigenerational home renovation tax credit (MGHRTC) would apply to the construction of an accessory dwelling unit such as carriage house or a laneway house. ...

19 December 2023 External T.I. 2023-0974871E5- METC-Interocular lens & prepaid medical expenses. ... Underhill, CPA, CGA December 19, 2023 Dear XXXXXXXXXX: Re: Amounts paid for interocular lens & prepaid medical expenses We are writing in response to your correspondence received on February 14, 2023, asking whether the cost you incurred for an interocular lens as part of cataract surgery qualifies as an eligible medical expense for the purposes of the medical expense tax credit (METC). ...

5 March 2024 External T.I. 2023-0962831E5- Active business income – Income from solar panels Unedited CRA Tags 125(1), 125(7) “income of the corporation for the year from an active business”, “active business carried on by a corporation”, “personal services business”, “specified investment business”, 129(4) “income or loss”, 248(1) “business”, “property" Principal Issues: Whether income earned by a corporation from selling electricity generated from solar panels would be active business income eligible for the small business deduction pursuant to subsection 125(1) of the Income Tax Act. ... XXXXXXXXXX Income Tax Rulings Directorate Ryan Wallace, CPA 2023-096283 March 5, 2024 Dear XXXXXXXXXX: Re: Active Business Income – Income received from selling electricity generated from solar panels We are writing in response to your email of February 3, 2023, wherein you requested our views on whether income earned by a Canadian-controlled private corporation (the “Corporation”) from selling electricity generated from solar panels would be considered active business income (“ABI”) eligible for the small business deduction (“SBD”) in subsection 125(1) of the Income Tax Act (“Act”). ...