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Summary of 2022 Ruling 2021-0904611R3 F under s. 248(1) – deposition – (f). ...

Summary of 9 August 2023 External T.I. 2023-0979431E5 under Reg. 1206(1) – CEDOE – para. ...

(j.1) of the financial service definition exempts “the service of providing an insurer … with an appraisal of the damage caused to property, or in the case of a loss of property, the value of the property, where the supplier of the appraisal inspects the property, or in the case of a loss of the property, the last-known place where the property was situated before the loss.” ... Summary of 20 December 2018 Ruling 189221 under ETA s. 123(1) – financial service – para. ...

16 October 2019- 11:30pm CRA finds that a transfer of a TFSA to the surviving spouse because of their daughter’s renunciation occurred as a consequence of the deceased’s death Email this Content Although an individual made a specific bequest under his will of his TFSA to his adult daughter, she executed a written renunciation of the bequest (that CRA went on to find was deemed by s. 248(9) to result in a “disclaimer” or a “release or surrender” for purposes of s. 248(8)(b),) so that following the TFSA's liquidation by the executor, the proceeds were instead transferred by the executor to the widow of the deceased – who then promptly contributed such proceeds to her own TFSA. ... Summary of 11 October 2019 APFF Financial Strategies and Instruments Roundtable, Q.6 under s. 207.01(1) – exempt contribution – (b). ...

CRA indicated that this exclusion applied where the corporation in question (which presumably is paying dividends to a specified individual who was never relevantly engaged in its business) has in a previous year sold its business to an arm’s length corporation which continues to actively carry on that business – unless the source individual in question continues an active involvement in that business, for example, under a transitional services business, in which case the related business exception would not be available to the specified individual. ... Summary of 3 December 2019 CTF Roundtable, Q.9 under s. 120.4(1) – related business – (a)(ii). ...

Accordingly … business interruption insurance proceeds would generally be included in qualifying revenue and would generally not be considered an extraordinary item. ... Summary of 3 May 2021 Internal T.I. 2020-0852571I7 under s. 125.7(1) – qualifying revenue – (c). ...

" Allen JA stated that, as “the purpose of the treaty is to avoid double taxation … it stands to reason that it should only apply to persons who otherwise would be exposed to a liability to pay tax. ... Summary of Revenue Commissioners v Susquehanna International Group Ltd & ors [2025] IECA 123 under Treaties – Income Tax Conventions – Art. 4. ...

Where the value of the participant’s electricity consumption is less than the value of the electricity supplied, it generates credit, which is available for use against its future electricity consumption in the next billing period – but to the extent that the accumulated credit cannot be used within a given 12-month period, it will then be forfeited. ... Summaries of 17 January 2020 External T.I. 2017-0685341E5 under s. 9 – computation of profit, s. 3 – business source, Sched. II – Class 43.1 and Reg. 1100(25). ...

Summaries of Josh Jones and Jeffrey Love, "Recent Developments in Asset Management", draft 2023 CTF Annual Conference paper under s. 132(5.3)(a), s. 132(5.3)(b), s. 104(7.1), s. 132(4) – capital gains redemption, s. 132(5.31), s. 251.1(2)(b), s. 251.2(1) – investment fund, s. 18.2(1) – excluded entity – (c), eligible group entity, adjusted taxable income, and s. 94(1)- fixed interest. ...

(c) of the EP definition refers to property of the FA “all or substantially all of the income from which is … income from an active business.” ... Summaries of Tina Korovilas and Drew Morier, “Non-Corporate Vehicles in the Foreign Affiliate Context,” Canadian Tax Foundation, 2018 Conference Report, 20:1 – 114 under s. 96, s. 104(1), Reg. 5907(11.2)(b), s. 90(1), s. 93.1(2)(a), s. 93.1(2)(d)(i), Reg. 5901(2)(b)(ii), s. 93(1.3), s. 95(1) – excluded property – para. ... (c), s. 95(2)(y), s. 95(2)(z), s. 95(2)(a)(ii)(B)(II), s. 95(2)(a)(ii)(D) and s. 94(1) – exempt foreign trust – (h)(ii)(C)(I). ...