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Bundle Translated severed letter Summaries under Summary descriptor 2016-11-16 24 June 2016 External T.I. 2015-0571471E5 F- Passe de ski familiale Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) no taxable benefit if all employees given season’s pass at ski resort/gift policy also applicable 2 August 2016 External T.I. 2014-0544941E5 F- Interaction between ss. 111(12) and 80.01(3) Income Tax Act- Section 80.01- Subsection 80.01(3) deemed settlement under 80.01(3) before operation of 111(12) Income Tax Act- Section 111- Subsection 111(12) no accrued FX loss on a loan owing by a target to a sub is realized on an AOC where there is a same-day amalgamation and no time-stamping 2016-10-19 22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) inter-affiliate loan generating deemed active business funded out of an interest-free loan from Canco Income Tax Act- Section 248- Subsection 248(5) ordinary meaning of “substituted” Income Tax Act- Section 93- Subsection 93(2.01) a contribution of FA1 shares to FA2 causes the FA2 shares to be substituted property for s. 93(2.01) purposes 2016-01-20 3 December 2015 External T.I. 2015-0593941E5 F- Allocation of the safe income on hand General Concepts- Fair Market Value- Shares FMV of discretionary share increased at moment of dividend declaration to exclusion of other discretionary shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) flexible allocation of SIOH where discretionary common shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) quaere whether 8% reduction is significant 26 March 2015 Internal T.I. 2013-0503031I7 F- Existence d’une source de revenu Income Tax Act- Section 3- Business Source/Reasonable Expectation of Profit individual’s sideline activity not a business so that revenues exempt Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose criteria for determining whether a home is a principal place of business 8 December 2015 External T.I. 2015-0616321E5 F- CEE- Severance pay Income Tax Regulations- Regulation 1206- Subsection 1206(1)- Canadian exploration and development overhead expense exclusion of severance payment Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (a) severance payment not includible in CEE 8 June 2015 External T.I. 2014-0529851E5 F- Frais payés à une maison de santé ou de repos Income Tax Act- Section 118.2- Subsection 118.2(1) expenses can be claimed based on 12-month period ending in year Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(d) floor of retirement residence servicing those with advanced Alzheimer’s can qualify as “nursing home” Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(e) no 2nd credit under s. 118.3 re accommodation expenses in nursing home 11 December 2015 External T.I. 2015-0601561E5 F- Attribution Rules Income Tax Act- Section 74.4- Subsection 74.4(2) annual dividends by an SBC to a non-SBC are not an indirect transfer of property to the non-SBC by the individual who formed the SBC ...

T.I. 2012-0463801E5 F- Déduction pour gain en capital – permis de pêche Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(b) para. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2017-03-15 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.1, 2016-0674221C6 F- General deduction from tax- 123.4 Income Tax Act- Section 123.4- Subsection 123.4(1)- Full Rate Taxable Income income on which the SBD was not claimed nonetheless is not eligible for the general rate deduction 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.2, 2017-0682711C6 F- Dedicated Telephone Service for Income Tax Service Income Tax Act- Section 152- Subsection 152(1) telephone service for those with complex technical tax issues will initially be limited to Ontario and Quebec CPAs 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.3, 2016-0674821C6 F- Individuals separated living under the same roof Income Tax Act- Section 122.6- Cohabiting Spouse or Common-Law Partner couple under the same roof can be living separate and apart Income Tax Act- Section 248- Subsection 248(1)- Common-Law Partner meaning of living "separate and apart" 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.4, 2016-0674831C6 F- Changement d'usage- duplex Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(c) substantially renovating the personal-use portion of a rental property (without changing floor areas) generally would not engage the change-of-use rules Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) apportionment of operating expenses of duplex used both personally and for rental income Income Tax Act- Section 248- Subsection 248(1)- Property duplex is single property 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.5, 2016-0674801C6 F- Allocation et frais d'une automobile Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(k)- Subparagraph 6(1)(k)(v) electric vehicles treated the same Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) general reasonability of a car allowance rate of $0.54/$0.48 per kilometre including for electric vehicles 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.6, 2016-0674861C6 F- Wholly dependent person tax credit Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b)- Subparagraph 118(1)(b)(ii) meaning of support/legal custody not required/ITA is silent on number of days child must spend with parent 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.7, 2016-0674811C6 F- Allocations automobiles & dépenses afférentes Income Tax Regulations- Regulation 200- Subsection 200(3) correction of T4s Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) if vehicle allowance is too low, employee can include the allowance and deduct the vehicle expenses/T2200 production expected 2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.8, 2016-0674851C6 F- HBTC- Acquisition by way of gift Income Tax Act- Section 118.05- Subsection 118.05(1)- Qualifying Home gifted home can qualify for the HBTC ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2018-04-25 12 June 2017 Internal T.I. 2016-0679291I7 F- Régime d’assurance décès et mutilation accidentels Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(e.1) the payment of group accident plan premiums by an employer for its benefit gave rise to taxable benefits 2018-04-11 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 1, 2017-0705221C6 F- Property transfers- common law partners in Québec Income Tax Act- Section 146- Subsection 146(16)- Paragraph 146(16)(b) a common-law partners’ separation agreement can engage s. 146(16)(b) or 146.3(14) rollover even if technically they have no legal rights to settle Income Tax Act- Section 73- Subsection 73(1.01)- Paragraph 73(1.01)(b) rollover under common-law partners' separation agreement irrespective of whether technically they have separation rights to settle Income Tax Act- Section 146.3- Subsection 146.3(14) rollover pursuant to common-law partners' settlement agreement 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2017-0710681C6 F- Withdrawal of RRSP over-contributions after death Income Tax Act- Section 146- Subsection 146(8.8) income inclusion under s. 146(8.8) on death irrespective whether premiums exceeded deductible amount Income Tax Act- Section 146- Subsection 146(8.2) deemed s. 146(8.8) benefit on death treated as RRSP withdrawal, and executor should not use Form T746 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 4, 2017-0707781C6 F- Withdrawal of undeducted RRSP contributions Income Tax Act- Section 146- Subsection 146(8.2) s. 146(8.2) deduction for withdrawing excess contributions can be available even where Pt X.1 tax is not applicable 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 5, 2017-0707801C6 F- RRIF transfers – partition of family patrimony Income Tax Act- Section 146.3- Subsection 146.3(14) amount paid to surviving spouse's RRIF did not qualify under s. 146.3(14) Income Tax Act- Section 146.3- Subsection 146.3(1)- Designated Benefit payment from a deceased’s RRIF to the RRIF of the surviving spouse who was excluded under the will qualified as designated benefit Income Tax Act- Section 60- Paragraph 60(l) transfer from deceased's RRIF to RRIF of surviving spouse in settlement of claim 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 6, 2017-0707791C6 F- RRIF- Successive Deaths Income Tax Act- Section 146.3- Subsection 146.3(1)- Designated Benefit death of the surviving spouse before she received payment of the testator’s legacy of his RRIF precluded access to the designated benefit rules Income Tax Act- Section 146.3- Subsection 146.3(6.1) s. 146.3(6.1) did not apply as the executor did not receive the RRIF legacy ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2013-05-15 23 November 2012 External T.I. 2012-0449101E5 F- Production exclue- CIPCMC Income Tax Regulations- Regulation 1106- Subsection 1106(1)- Excluded Production- Paragraph (a)- Subparagraph (a)(iii)- Clause (a)(iii)(A) 5-year test was violated when successor to production company became controlled by an unrelated person 13 September 2012 Internal T.I. 2012-0442671I7 F- Dédommagement pour la perte de bénéfices Income Tax Act- Section 248- Subsection 248(1)- Death Benefit damages received for loss of life insurance coverage were not rendered a death benefit under the surrogatum principle Income Tax Act- Section 6- Subsection 6(3) damages received by former employees of insolvent company for cancellation of their life insurance coverage were received in lieu of remuneration for their employment services Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(b) legal fees paid to recover damages for employer cancellation of insurance coverage, and medical plan, qualifed and did not qualify, respectively Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) damages received after 2011 by employees of an insolvent company for cancellation of their medical plan have become taxable 6 December 2012 External T.I. 2012-0461711E5 F- Paiements indirects / Indirect payments Income Tax Act- Section 56- Subsection 56(2) 56(2) inapplicable to incorporated artist respecting producer paying mandatory contributions to the fund for the artist’s union Income Tax Regulations- Regulation 200- Subsection 200(1) no T4A slip to be issued by producer paying mandatory contributions to the fund for the union of the artist whose corporation receives fees from the producer 18 April 2013 Internal T.I. 2013-0485481I7 F- Balance of sale price without interest Income Tax Act- Section 16- Subsection 16(1) s. 16(1) inapplicable if sale price including non-interest bearing balance does not exceed sold assets’ FMV 21 January 2013 Internal T.I. 2012-0442021I7 F- Assessing 163(2) penalty Income Tax Act- Section 163- Subsection 163(2)- Paragraph 163(2)(c.2) penalty is computed on total RMES adjustment, not just the false portion Income Tax Act- Section 163- Subsection 163(2)- Paragraph 163(2)(c) false RMES claim by husband does not generate any penalty for resulting overstatement of CCTB, WITB and GSTC by wife, assuming she made no false statement Income Tax Act- Section 163- Subsection 163(2)- Paragraph 163(2)(a)- Subparagraph 163(2)(a)(i) deduction against increase to income attributable to a false statement can be reduced by QPP contribution increase or by discretionary CCA claim that is wholly related to that income source 20 March 2013 Internal T.I. 2012-0463181I7 F- Revenu des entrepreneurs Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(b) completion method unavailable for communication and electricity structure installations ...

These are additions to our set of 861 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 ¼ years of releases by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2019-07-31 12 June 2019 External T.I. 2019-0792011E5 F- TOSI definition excluded shares Income Tax Act- Section 120.4- Subsection 120.4(1.1)- Paragraph 120.4(1.1)(d) income derived from related business included income from reinvesting sales proceeds from sale thereof in preceding year Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares- Paragraph (c) two years were required to pass before proceeds from the sale of a related business could generate excluded share income for TOSI purposes 13 August 2018 Internal T.I. 2018-0763611I7 F- Subpar 152(4)(b)(iii) and FAPI Income Tax Act- Section 152- Subsection 152(4.01)- Paragraph 152(4.01)(b)- Subaragraph 152(4.01)(b)(iii) reassessment of FAPI from marketable securities related to their previous contribution by the taxpayer Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(b)- Subparagraph 152(4)(b)(iii) the extended reassessment period can apply to FAPI earned even before the 2018 Budget 2011-11-04 7 October 2011 Roundtable, 2011-0411951C6 F- Retenues à la source- options d'achat d'actions Income Tax Regulations- Regulation 6204- Subsection 6204(1)- Paragraph 6204(1)(a) conferral on employer of share repurchase right to set off against source deduction obligation engages the exclusion Income Tax Regulations- Regulation 6204- Subsection 6204(1)- Paragraph 6204(1)(b) loss of prescribed share status where employer granted redemption right to cover s. 153(1.01) withholding obligations Income Tax Act- Section 153- Subsection 153(1.01) treatment of net share issuances under review 7 October 2011 Roundtable, 2011-0408251C6 F- REER, règle d'attribution, retenues à la source Income Tax Act- Section 146- Subsection 146(8.3) s. 146(8.3) applied since not yet separated at time of withdrawal even though withholding for account of spouse Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(j) application of s. 153(1)(j) not affected by application of s. 146(8.3) 7 October 2011 Roundtable, 2011-0399401C6- Butterfly, life insurance policies, grandfathering Income Tax Act- Section 55- Subsection 55(4) s. 55(4) in applicable if the principal reason for parent’s control of DC was parent's economic interests Income Tax Act- Section 55- Subsection 55(1)- Distribution CSV of life insurance policy was a cash asset- FMV excess could be an investment asset if no cash-out intention Income Tax Act- Section 55- Subsection 55(3.1)- Paragraph 55(3.1)(a) a policy loan under a life insurance policy to reduce its CSV would trigger s. 55(3.1)(a) 7 October 2011 Roundtable, 2011-0413081C6 F- 227(4) et (4.1)- vente d'un bien à un tiers Income Tax Act- Section 227- Subsection 227(4.1) deemed trust applies only to sales proceeds (but such a purchaser does not include a seizing creditor) Income Tax Act- Section 227- Subsection 227(4) deemed trust is a universal floating charge that traces through to sales proceeds 7 October 2011 Roundtable, 2011-0412161C6 F- Timing of the increase in interest- stock option Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a)- Subparagraph 55(3)(a)(ii) grant of in-the-money options to key employee as part of same series could be a significant increase in interest – which otherwise occurs on exercise 7 October 2011 Roundtable, 2011-0399421C6 F- Options, biens identiques, PBR Income Tax Act- Section 7- Subsection 7(1.3) application of s. 47(1) takes s. 7(1.3) into account 7 October 2011 Roundtable, 2011-0399441C6 F- T1135- coût indiqué d'une assurance-vie Income Tax Act- Section 233.3- Subsection 233.3(1)- Reporting Entity cost amount of foreign policy is its adjusted cost basis Income Tax Act- Section 248- Subsection 248(1)- Cost Amount- Paragraph (f) adjusted cost basis of policy is generally its “cost” under para. ...

These are additions to our set of 1,187 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 ¾ years of releases of Interpretations by the Directorate. ...

Summary of 8 April 2020 External T.I. 2020-0839581E5- "Excluded Shares" under s. 120.4(1) – excluded shares- (c). ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2021-03-10 23 June 2020 External T.I. 2020-0849221E5 F- SSUC- Entité déterminée et institution publique Substantially the same as 2020-0848721E5 F 23 June 2020 External T.I. 2020-0849211E5 F- SSUC- Entité déterminée et institution publique substantially the same as 2020-0848721E5 F 2009-01-09 16 December 2008 Internal T.I. 2008-0300361I7 F- Déductibilité de l'impôt minimum sur les sociétés Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Ontario CMT is non-deductible 2009-01-02 16 December 2008 External T.I. 2008-0279741E5 F- Renonciation au capital d'une fiducie Income Tax Act- Section 56- Subsection 56(4) s. 56(4) inapplicable to disclaimer of capital interest in a trust Income Tax Act- Section 54- Proceeds of Disposition settlor’s renunciation of capital interest (but not income interest) prior to trustees’ exercise of discretion to distribute a capital gain would generate nil proceeds and not engage s. 56(2) or (4) Income Tax Act- Section 69- Subsection 69(1)- Paragraph 69(1)(b) s. 69(1) does not apply to a renunciation of trust capital interest since no disposition "to" any person Income Tax Act- Section 75- Subsection 75(2) settlor’s valid renunciation of capital interest (but not income interest) prior to trustees’ exercise of discretion to distribute a capital gain would avoid application of s. 75(2)(a)(i) Income Tax Act- Section 248- Subsection 248(9)- Disclaimer legally impossible for a beneficiary of a discretionary trust to partially renounce income from a specific trust property Income Tax Act- Section 56- Subsection 56(2) s. 56(2) inapplicable to renunciation of capital interest in a trust Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (i) non-disposition distribution of non-taxable portion of trust capital gains avoids a gain under s. 107(2.1) 19 December 2008 External T.I. 2008-0299321E5 F- Exploitation forestière et DBFT Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits managing processing operation of another corp. did not qualify Income Tax Regulations- Regulation 5202- Cost of Manufacturing and Processing Labour fees of another corp. for managing the taxpayer’s log processing operation could qualify as "cost of manufacturing and processing labour" 2008-12-19 8 December 2008 External T.I. 2008-0264691E5 F- GRIP Addition/ Majoration CRTG Income Tax Act- Section 89- Subsection 89(7)- Element A- Paragraph (c) dividends of full rate taxable income from sub to parent generated addition to parent’s GRIP addition 2008-12-12 2 December 2008 External T.I. 2008-0301761E5 F- Prepayment of Reassessments- Refund Interest Income Tax Act- Section 164- Subsection 164(3) CRA will accept an advance payment of a genuinely anticipated reassessment so as to subsequently generate interest on the advance’s refund 2008-11-07 30 October 2008 External T.I. 2006-0198381E5 F- Disposition d'un BUP- application de l'article 42 Income Tax Act- Section 42- Subsection 42(1)- Paragraph 42(1)(b) payment of claim re latent defect in principal residence generated a s. 42 capital loss – that was denied by s. 40(2)(g)(iii) 28 October 2008 External T.I. 2008-0274281E5 F- Société gestion de pension, moyen de financement Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.1)- Subparagraph 149(1)(o.1)(i)- Clause 149(1)(o.1)(i)(A) 2-pronged test Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.1)- Subparagraph 149(1)(o.1)(ii) to be accepted, the corporation must hold property rather than only manage 30 October 2008 External T.I. 2008-0286141E5 F- Prestations de retraite reçues par un Indien Other Legislation/Constitution- Federal- Indian Act- Section 87 exempt portion of pension payments determined based on exempt portions of employment as entitlements thereto accrued 2008-10-31 24 October 2008 External T.I. 2008-0278661E5 F- Allocation pour frais de déplacement Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(v) travel to cover “a very great distance” between the employee’s regular work place and the employer’s place of business (a hotel meeting room) is in the course of the employment ...