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These are additions to our set of 2,363 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ¼ years of releases of such items by the Directorate. ...

Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) payment of deferred commission amounts held as contingency loss reserve from old employer to new employer was a payment of “remuneration” subject to withholding General Concepts- Payment & Receipt constructive receipt by employee where reserve loss account (funded out of commissions) is transferred from old brokerage employer to new brokerage employer 2003-10-03 24 September 2003 External T.I. 2003-0028145 F- DON FAIT PAR UN PARTICULIER NON-RESIDENT Also released under document number 2003-00281450. ...

These are additions to our set of 2,417 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,445 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,458 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ¾ years of releases of such items by the Directorate. ...

Income Tax Act- Section 5- Subsection 5(1) salary that is forfeited by RCMP officer for misconduct nonetheless is includible as salary which was constructively received General Concepts- Payment & Receipt forfeited salary nonetheless includible as salary received ...

Topic Descriptor 17 May 2023 IFA Roundtable Q. 1, 2023-0964391C6- stock based compensation and transfer pricing Income Tax Act- Section 7- Subsection 7(3)- Paragraph 7(3)(b) s. 7(3)(b) non-deduction or s. 112(1)(e) deductibility could apply to cross-border stock option recharges of non-resident parent Income Tax Act- Section 247- New- Subsection 247(2) stock-compensation expenses may be relevant to pricing cross-border services charges even where s. 7(3)(b) prohibits their deduction 17 May 2023 IFA Roundtable Q. 2, 2023-0964301C6- Ukraine Russia FAs and Tax Reporting Income Tax Act- Section 233.5 failure to file complete information for affiliate in war-torn country Income Tax Act- Section 220- Subsection 220(2.1) potential relief from return-filing requirements re FA in war-torn country 17 May 2023 IFA Roundtable Q. 3, 2023-0964551C6- T1134 Supplement Income Tax Act- Section 233.5 T1134 should be timely-filed with missing information noted Income Tax Act- Section 90- Subsection 90(2) a pro rata distribution by an LLLP to its members is a dividend 17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Treaties- Income Tax Conventions- Article 29 Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion 17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6- Remote Work Arrangements Income Tax Act- Section 253- Paragraph 253(b) s. 253(b) does not extend to “invitation to treat” or advertisement Income Tax Act- Section 253- Paragraph 253(a) product development from Canadian home office might engage s. 253(a) Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) whether Canadian home offices of US employees can give rise to it carrying on business in Canada Treaties- Income Tax Conventions- Article 5 whether employee’s home office can constitute a PE of US employer 17 May 2023 IFA Roundtable Q. 6, 2023-0964351C6- Application of the Canada-US Treaty Treaties- Income Tax Conventions- Article 4 Treaty benefits could be created for a s. 216 structure by creating partnerships for US purposes 15 September 2020 IFA Roundtable Q. 7, 2020-0853571C6- Regulation 5901(2)(b) Pre-Acquisition Surplus Election Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b)- Subparagraph 5901(2)(b)(ii) Reg. 5901(2)(b)(ii)(A) does not taint a siloed dividend paid by FA to Canco1 even though another Canco holds other FA shares through an LP 17 May 2023 IFA Roundtable Q. 7, 2023-0964521C6- Application of Article 10, Canada-Hong Kong Treaties- Multilateral Instrument- Article 7- Article 7(1) the PPT object and purpose test is met where individuals in a Treaty country transfer their Canco shares to a Treaty-resident Holdco to reduce dividend withholding Treaties- Income Tax Conventions- Article 10 violating main purpose test in HK Treaty increases dividend rate/ PPT object and purpose test not violated by using personal holding company in same jurisdiction 17 May 2023 IFA Roundtable Q. 8, 2023-0964561C6- Tax-free Surplus Balance and Paragraph 88(1)(d) Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(d)- Subparagraph 88(1)(d)(ii)- Variable C surplus computation not required in typical bump and run transaction Income Tax Regulations- Regulation 5905- Subsection 5905(5.4) no surplus calculations needed where FA of Canadian target is acquired by Forco through a Cdn. ...

These are additions to our set of 2,577 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-10-11 28 October 2002 External T.I. 2002-0134785 F- Partitioning of Shares Income Tax Act- Section 248- Subsection 248(1)- Property interest in trust is a single property even if held as units Income Tax Act- Section 248- Subsection 248(20) s. 248(20) might apply if a partition results in the issuance of whole shares Income Tax Act- Section 248- Subsection 248(21) s. 248(21) could apply to partitioning a share if the corporation could issue fractional shares on the partition satisfying the FMV test, and similarly for partitioning MFT units (viewed as a single property) Income Tax Act- Section 98- Subsection 98(3) partners not permitted to receive divided interest in shares on s. 98(3) wind-up 28 October 2002 External T.I. 2002-0117595 F- REVENU EXPERT-COMPTABLE Income Tax Act- Section 9- Nature of Income accountants required to individually recognize professional income earned by them as employees of an NPO corporation 2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103 Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) 25 October 2002 External T.I. 2002-0137705 F- Butterfly Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(e) CCRA will permit UCC to be split on a pro rata basis under s. 85(1)(e)(i) where the butterfly entails s. 85(1) drop-downs to Newco subs of DC followed by their transfers to TCs 4 November 2002 Internal T.I. 2002-0160697 F- REPARTITION DU PLAFOND Income Tax Act- Section 125- Subsection 125(5)- Paragraph 125(5)(a) s. 125(5)(a) did not apply to a CCPC for its 2nd 2000 taxation year resulting from an acquisition of control causing it to be associated with a different CCPC 22 October 2002 External T.I. 2002-0162835 F- Recbles Recd. after Disp. of Farm. ...

Income Tax Act- Section 50- Subsection 50(1)- Paragraph 50(1)(b)- Subparagraph 50(1)(b)(iii)- Clause 50(1)(b)(iii)(A) “insolvent” means unable to pay one’s debts/ can’t be insolvent if nil liabilities and assets 25 February 2002 Internal T.I. 2001-0114167 F- DOMMAGES- DISCRIMINATION Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance compensation under the CHRA for lost wages and expenses would be a retiring allowance – reasonable (e.g., under $5,000) compensation for pain and suffering would be non-taxable Income Tax Act- Section 3- Paragraph 3(a) awards by human rights tribunals for pain and suffering re wrongful termination often are under $5,000 ...