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Bundle Date Translated severed letter Summaries under Summary descriptor 2011-09-23 6 September 2011 External T.I. 2010-0389011E5 F- L'interprétation de " est en droit de recevoir" Income Tax Act- Section 13- Subsection 13(7.1) taxpayer is entitled to receive Quebec M&P credit at end of year in which the eligible expenditures were incurred 12 September 2011 External T.I. 2011-0397731E5 F- Crédit d'impôt pour frais médicaux Income Tax Regulations- Regulation 5700- Section 5700- Paragraph 5700(h) "hospital bed" does not extend to all types of adjustable beds Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) aquatherapy classes (or pain management courses) do not qualify if non-qualified payee 16 August 2011 Internal T.I. 2011-0401721I7 F- Loss Utilization Income Tax Act- Section 88- Subsection 88(1.1)- Paragraph 88(1.1)(e) factors in determining whether investments are held as a business Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) holding company whose only sources of income were inter-affiliate loan and subsidiary shares had losses from property rather than business 2011-09-16 6 September 2011 Internal T.I. 2011-0401191I7 F- Automobiles mises à la disposition des employés Income Tax Act- Section 6- Subsection 6(2) standby not computed for months in which automobiles in storage and unavailable for use 2 September 2011 Internal T.I. 2011-0419111I7 F- Programme de compensation du MESS Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(u) social assistance payments aggregating less than $500 not required to be included in income 31 August 2011 External T.I. 2011-0416541E5 F- Montant admis en déduction- REÉR Income Tax Act- Section 146- Subsection 146(5) if premium not claimed, deduction amount is nil 2011-09-09 31 August 2011 External T.I. 2011-0415891E5 F- Increase in stated capital, stock dividends-55(2) Income Tax Act- Section 248- Subsection 248(28) s. 248(28)(a) applied to reduce capital gain on disposition of preferred shares on which a capital gain had been realized under s. 55(2)(b) Income Tax Act- Section 55- Subsection 55(2)- Paragraph 55(2)(c) capital gain recognized under s. 55(2)(c) not recognized a second time on sale of the shares ...

These are additions to our set of 981 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¼ years of releases of Interpretations by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-06-24 15 June 2011 Internal T.I. 2011-0405501I7 F- Withholding- stock option benefits Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) withholding obligation extends to stock option benefits Income Tax Act- Section 153- Subsection 153(1.1) it is up to employer to find a solution for need to withhold from s. 7 benefits 8 October 2010 Roundtable, 2010-0371911C6 F- Biens dévolus au conjoint Income Tax Act- Section 70- Subsection 70(6) no rollover for bequested shares that had to be sold to satisfy estate debts 10 June 2011 Roundtable, 2011-0404621C6 F- Rectification order in Québec General Concepts- Rectification & Rescission CRA awaiting resolution of AES and Riopel cases 9 June 2011 Internal T.I. 2011-0396721I7 F- Déduction- habitants de régions éloignées Income Tax Act- 101-110- Section 110.7- Subsection 110.7(1) regular absences of 8 days on a 43-day cycle did not interrupt “residence” in zone 2011-06-17 9 June 2011 Internal T.I. 2011-0395001I7 F- Co-propriété indivise d'un duplex Income Tax Act- Section 54- Principal Residence- Paragraph (a) 2 equal co-owners of duplex could each claim the principal residence exemption for “their” unit General Concepts- Fair Market Value- Land although each 50% co-owner of a duplex has an undivided interest in the whole dwelling, the FMV of her interest relates exclusively to the housing unit occupied by her General Concepts- Ownership co-ownership interest is in the whole but valuation of the part occupied should reflect rights of exclusive possession 7 June 2011 Internal T.I. 2011-0397921I7 F- Financement inter-sociétés Income Tax Act- Section 15- Subsection 15(2.1) notwithstanding Gillette, a connected “person” may include a partnership Income Tax Act- Section 227- Subsection 227(6.1) refund of withholding tax on repayment of loan Income Tax Act- Section 80.4- Subsection 80.4(3)- Paragraph 80.4(3)(b) s. 80.4 would not apply to a s. 15(2) loan if it is not repaid ...

These are additions to our set of 1,005 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ½ years of releases of Interpretations by the Directorate. ...

These are additions to our set of 1,011 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ½ years of releases of Interpretations by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-05-06 13 April 2010 External T.I. 2010-0382791E5 F- Logement offert gratuitement à un pasteur Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) occupation of free housing after ceased to be pastor not taxable if not in exchange for services 2011-04-29 4 April 2011 External T.I. 2010-0388741E5 F- Société quittant le Canada Income Tax Act- Section 250- Subsection 250(5.1) no requirement to file Canadian returns following continuance 22 March 2011 Internal T.I. 2010-0387551I7 F- Dépenses- travailleur indépendant Income Tax Regulations- Schedules- Schedule II- Class 8- Paragrpah 8(i) erotic costumes used on website did not qualify Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h) expenses of costumes, breast implants and rejuvenation expenses of erotic website were non-deductible 2011-04-22 8 October 2010 Roundtable, 2010-0373201C6 F- Change of Control and Amalgamation Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(a) CRA will respect out-of-ordinary course transactions that logically occur between AOC and amalgamation as being effected by predecessor 2011-04-08 30 March 2011 External T.I. 2010-0390591E5 F- Cotisation spéciale Income Tax Act- Section 9- Timing amounts assessed against the taxpayer by co-owners not deductible until expended on or in the business Income Tax Act- Section 248- Subsection 248(16)- Paragraph 248(16)(a)- Subparagraph 248(16)(a)(i) addition for GST and subtraction for ITC General Concepts- Payment & Receipt amounts paid by set-off are both paid even though no movement of funds 8 October 2010 Roundtable, 2010-0373501C6 F- Al. 212(9)d) proposé- remboursement Income Tax Act- Section 212- Subsection 212(9)- Paragraph 212(9)(d) need for alteration of 2-year limitation in s. 227(5) in order to recover tax back to 2000 ...

These are additions to our set of 1,029 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¾ years of releases of Interpretations by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-02-25 8 October 2010 Roundtable, 2010-0373161C6 F- Paragraphs 256(3) and 256(6) ITA Income Tax Act- Section 256- Subsection 256(6) application could prevent acquisition of control or preclude loss of CCPC status 8 October 2010 Roundtable, 2010-0373191C6 F- Computation of safe income Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) where interest in partnership holding Subco with safe income is rolled into Holdco for prefs, dividends from Subco do not change consolidated SIOH of prefs – or increase commons’ SIOH 2011-02-18 8 October 2010 Roundtable, 2010-0373131C6 F- Présomption d'action concertée Income Tax Act- Section 251.2- Subsection 251.2(2)- Paragraph 251.2(2)(a) Q of fact re whether 3 or more CCPC shareholders form a group 9 December 2010 Internal T.I. 2010-0371741I7 F- Automobiles mises à la disposition des employés Income Tax Act- Section 248- Subsection 248(1)- Automobile qualification as automobiles turns on design, not use Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(e) employer-provided automobile to attend occasional off-site meetings did not generate a benefit 24 January 2011 Internal T.I. 2010-0389251I7 F- Farm-out agreement and warrants Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (j) CEE to be incurred under simple farmout reduced by an allocation to warrants issued by farmee Income Tax Act- Section 15- Subsection 15(1) valuation of “free” warrants issued as part of a simple farmout agreement determined based on what would be a s. 15(1) benefit General Concepts- Fair Market Value- Options amount allocated out of consideration to “free” warrants based on the greater of their trading and in-the-money value Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) application of farmout policy to situation where free warrants issued along with incurring of CEE ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-01-28 5 January 2011 Internal T.I. 2010-0389761I7 F- Application du paragraphe 162(7.01) Income Tax Act- Section 162- Subsection 162(7.01) s. 162(7.01) penalty is cumulative with (7.02). and is computed aggregating base and summary slips and both are computed from initial final deadline if s. 220(3) deadline is missed 2011-01-07 1 December 2010 External T.I. 2010-0385491E5 F- Postes isolés dans la fonction publique Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan employer agreement to pay transportation costs from remote location re medical appointments could qualify as an exempt PHSP 2010-12-31 9 December 2010 External T.I. 2010-0364001E5 F- Ristourne de consommation, feuillet T4A Income Tax Act- Section 135- Subsection 135(7) no income inclusion re consumer goods or services Income Tax Regulations- Regulation 218 T4A required where annual payments in proportion to patronage exceed $500 2010-12-24 7 December 2010 External T.I. 2010-0363431E5 F- Date limite cotisation REER Income Tax Act- Section 146- Subsection 146(5) 60-day contribution deadline is met based on receipt of cheque by issuer, not its deposit General Concepts- Payment & Receipt RRSP premium “paid” when cheque received by issuer, not when it’s deposited 9 December 2010 External T.I. 2010-0388101E5 F- CCPC status and acquisition of control Income Tax Act- Section 249- Subsection 249(4)- Paragraph 249(4)(b) CCPC whose control has been agreed to be acquired by Pubco can elect to extend its deemed s. 249(3.1) year end under s. s. 249(4)(b) Income Tax Act- Section 249- Subsection 249(3.1) CCPC which has a December 26 deemed year end under ss. 249(3.1) and 251(1)(b) that is extended to December 31 under s. 249(4)(b) loses SBC for that extended year ...

These are additions to our set of 1131 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 ¼ years of releases of Interpretations by the Directorate. ...