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Principal Issues: Deductions available on optional returns under 70(2), 104(23)(d) & 150(4) 1. ... An RRSP deduction, like deductions for an ABIL, exploration & development, moving expenses, can only be claimed on the final return. ... Murphy for Director International and Trusts Division Income Tax Rulings Directorate c.c.: Wendy Coderre Partnerships Information Returns, Capital Gains, Deceased & RCA Specialty Publications Section Client Services Directorate ...

2 November 2015 External T.I. 2015-0594431E5- Ontario Energy & Property Tax Credit Principal Issues: Are land lease payments for a mobile home eligible for determining the Ontario Energy & Property Tax Credit? ... XXXXXXXXXX 2015-059443 George A Robertson, CPA CMA (905) 721-5196 November 2, 2015 Dear XXXXXXXXXX, This is in response to your letter dated June 2, 2015, enquiring whether the land lease cost paid by you can be used in the property tax amount of the calculation of the Ontario Energy & Property Tax Credit (“OEPTC”). ...

21 November 1994 Internal T.I. 9418117- TUITION & EDUCATION T. C. ... Principal Issues: whether tuition tax credit & education tax credit are available in respect of a university that is NOT designated under the Canada Student Loans program Position TAKEN: yes for both credits Reasons FOR POSITION TAKEN:-tuition tax credit-position stated in IT-516R-education tax credit- November 21, 1994 XXXXXXXXXX DISTRICT OFFICE Rulings Directorate XXXXXXXXXX A. ... While it is unlikely that subsection 118.6(1) of the Act was intended to deny a full time university student an education tax credit because of the lack of designation by the provincial authorities, a strict interpretation of the definition of "designated educational institution" in subsection 118.6(1) would suggest that a university or college which is not "... designated by the Lieutenant Governor in Council of a province as a specified educational institution under the Canada Student Loans Act, designated by an appropriate authority under the Canada Student Financial Assistance Act, or designated by the Minister of Higher Education and Science of the Province of Quebec for the purposes of An Act respecting financial assistance for students of the Province of Quebec... ...

30 June 1995 Internal T.I. 9514457- special purpose trust & taxable benefit from a trust Unedited CRA Tags 105(1) 149(1)(l) 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. ... Would payments made to the parent or guardian of a minor for trust approved expenses (for health, welfare, security & education) be taxable to the parent/guardian under 105(1)? ... Depending on the nature of the governing document, & if not set up to benefit public at large, it would not qualify as either a charity or NPO. ...

29 June 1992 Income Tax Severed Letter 9218045 F- REER — Remboursement de primes 24(1) 5-921804 Adèle St-Amour (613) 957-8953 A l'attention de 19(1) Le 29 juin 1992 Monsieur, Objet: Demande d'interprétation Projet de Loi C-80 La présente est en réponse à votre fac-similé du 12 juin 1992, nous demandant une interprétation relative à une modification proposée à l'alinéa 146(1)(h) de la Loi de l'impôt sur le revenu (ci-après "la Loi"). ... A cette fin, l'alinéa 46(1)h) précise qu'à moins de preuve du contraire, un enfant ou un petit-enfant n'est pas financièrement à la charge du rentier à son décès si, pour l'année qui précède celle du décès du rentier, un crédit pour personne à charge a été réclamé pour cet enfant ou petit-enfant par une personne autre que le rentier ou si le revenu pour l'année de l'enfant ou du petit-enfant dépassait 5 000 $. La clause 13 du projet de Loi C-80 propose qu'à compter de 1993, seuls les enfants dont le revenu dépasse le montant personnel de base pour l'année (6 456 $ pour 1992) précédant celle du décès du rentier seront présumés, sauf preuve du contraire, ne pas avoir été financièrement à la charge du rentier. ...

5 February 1988 Income Tax Severed Letter 7-2244- [] DATE: February 5 1988 TO SAINT JOHN, N.B. ... RULINGS POSITION The relevant portion of Class 29 of Schedule 11- Capital Cost Allowances, reads as follows: Property that would otherwise be included in another class in this Schedule (a) that is … property acquired by the taxpayer after May 8, 1972, (i) to be used directly or indirectly by him in Canada primarily in the manufacturing or processing of goods for sale or lease, or (...) and (b) that is (i) property that, but for this class, would be included in Class 8,... ...

3 March 2023 External T.I. 2022-0959251E5- Microprocessor knee prosthesis & the METC Unedited CRA Tags 118.2(2)(i) of the Act and 5700(i) of the Regulations Principal Issues: Whether the cost of a microprocessor knee prosthesis (or C-Leg) would be an eligible expense for the purpose of the medical expense tax credit. ... Reasons: The wording in paragraph 118.2(2)(i) which provides for amounts paid “for, or in respect of, an artificial limb […].” ... Information on how to claim the METC is available on the webpage titled “Lines 33099 and 33199 – Eligible medical expenses you can claim on your tax return.” ...

20 June 2023 STEP Roundtable Q. 14, 2023-0967371C6- s.70(6) & Application to Extend Principal Issues: (A) What is the process for making a written application to extend the 36 month period for property to become vested indefeasibly with the surviving spouse or common-law partner, or a testamentary spousal or common-law partner trust? ... (B) A written application should include details that provide the director of the legal representative’s tax services office with a clear picture of the reason for the extension request. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 14. ... One condition is that the deceased’s property vests indefeasibly with the surviving spouse or common-law partner, or a testamentary spousal or common-law partner trust: “…if it can be shown, within the period ending 36 months after the death of the taxpayer or, where written application therefore has been made to the Minister by the taxpayer's legal representative within that period, within such longer period as the Minister considers reasonable in the circumstances, that the property has become vested indefeasibly in the spouse or common-law partner or trust, as the case may be…” The T4011 Guide – Preparing Returns for Deceased Persons notes that if the legal representative needs more time to meet this condition, they can make a written request to the director at their tax services office before the end of the 36 month period. ...

23 January 2013 Internal T.I. 2012-0465081I7- Subsection 107(2) – a disposition by a NR Trust CRA Tags 107(2) 116 248(1) "disposition" Principal Issues: Does paragraph 107(2)(a) change the timing of the disposition for the purposes of section 116? ... Subsection 107(2) states: (2) Distribution by personal trust – Subject to subsections (2.001), (2.002) and (4) and (5), if at any time a property of a personal trust or a prescribed trust is distributed (otherwise than as a SIFT trust wind-up event) by the trust to a taxpayer who was a beneficiary under the trust and there is a resulting disposition of all or any part of the taxpayer's capital interest in the trust, (a) the trust shall be deemed to have disposed of the property for proceeds of disposition equal to its cost amount to the trust immediately before that time; (b) subject to subsection (2.2), the taxpayer is deemed to have acquired the property at a cost equal to the total of its cost amount to the trust immediately before that time and the specified percentage of the amount, if any by which… You request our views on whether paragraph 107(2)(a) deems a disposition of the property to occur immediately before the actual distribution from the non-resident trust to the beneficiary. ... The phrase "immediately before that time" as used in paragraph 107(2)(a) of the Act, qualifies only the words "... its cost amount to the trust... ...

27 October 1993 Administrative Letter 9326846 F- Minimum Tax & Net Capital Losses Unedited CRA Tags 127.52(1)(i)(ii)(A) Assessment of Returns Directorate Personal and General J.M. ... The three most obvious reasons why a taxpayer would not fully claim the net capital losses available to him in a particular taxation year are that a)     the taxpayer wishes to take advantage of the capital gains deduction under paragraph 110.6 of the Act, b)     the taxpayer's taxable income has already been reduced to nil by means of other deductions or c)     the net capital loss arises in a subsequent year and is not carried back to the taxation year in which the minimum tax arises. ...