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Technical Interpretation - External summary

12 November 2013 External T.I. 2012-0471621E5 F - Moving expenses - eligible relocation -- summary under Eligible Relocation

. If it is established on the facts that the taxpayer ordinarily occupied Residences 1, 2, and 3, the move from Residence 1 to Residence 2 is considered a relocation, and that from Residence 2 to Residence 3 as a second relocation. ...
Ruling summary

2014 Ruling 2014-0518521R3 - Issuance of a new class of units - Hedged Class -- summary under Subsection 104(7.1)

Accordingly, Fund 1 will purchase currency forward contracts (the "Canadian Hedging Contracts") solely in respect of the Hedged Class, and: The Hedged Class will have a return that is based on the performance of Fund 1's portfolio of investments without regard for the performance, either positive or negative, attributable to changes in value of the relevant foreign currency relative to the Canadian dollar because the foreign currency exposure of the portion of Fund 1 that is attributable to the Hedged Class will be substantially hedged using the Canadian Hedging Contracts. ...
Technical Interpretation - Internal summary

15 December 2014 Internal T.I. 2012-0445361I7 F - Remboursement de frais de déménagement -- summary under Paragraph 6(1)(a)

. If it is instead established on the facts that the taxpayer did not ordinarily reside at Location 2 before ordinarily residing at Location 3…[e]xpenses related to the sale of the residence at Location 1 would be considered expenses of the move from Location 1 to Location 3…. ...
Technical Interpretation - External summary

8 December 2015 External T.I. 2015-0613401E5 F - Attribution Rules -- summary under Subsection 74.4(2)

…[W]e refer you to… 2002-0147325 …. 2 nd Situation. Same as 1 st situation except that, rather than subscribing for preferred shares of Holdco, Opco declares a dividend on its common shares (held by Mr. ...
Conference summary

24 November 2015 CTF Roundtable Q. 11, 2015-0610711C6 - Impact of the Descarries decision -- summary under Subsection 245(4)

. The result...is that the tax-exempt margin made it possible for part of Oka’s surplus to be distributed to the appellants tax-free in a manner contrary to the object, spirit or purpose of section 84.1 of the Act. ...
Conference summary

24 November 2015 CTF Roundtable Q. 2, 2015-0610801C6 - Salary Deferral Arrangements -- summary under Paragraph 6801(d)

. For example, section 409A permits payments to be made as a result of a reduction in service to less than 20% of the previous level, a change in control of the employer or an unforeseeable emergency. ...
Technical Interpretation - External summary

3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income -- summary under Subsection 20(12)

A could under subsection 20(12) opt to claim, in his 2014 Canadian income tax return, an amount of up to $400…[which] would reduce the amount of his “non-business income tax” for 2014 …. ...
Technical Interpretation - External summary

22 November 2011 External T.I. 2011-0420451E5 F - Canadian resource property -- summary under Paragraph (e)

CRA indicated that it was not prepared to extend its policy on farm-in arrangements to this situation (given that “carrying out the work on the claims does not give a right in the claims but potentially only an option to acquire them”), stating: Consequently the amounts paid to carry out the work on the claims of Corporation B would be added to the cash payments provided for in the agreement and would be considered part of the overall consideration given by Corporation A to acquire a property. ...
Conference summary

7 October 2011 Roundtable, 2011-0420781C6 F - Transfert de RPA à un REER au décès. -- summary under Clause Subparagraph 60(l)(v)(B.01)

. We are not aware of any provisions of the Act permitting the division or allocation of tax withholding between a trust and its beneficiaries. ...
Technical Interpretation - Internal summary

7 January 2011 Internal T.I. 2010-0387011I7 F - DPA dans une année prescrite -- summary under Subsection 152(4)

…[T]he CRA should not accept the adjustment request as it would result in changes to the tax assessment for Year 1, which is a statute-barred year. ...

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