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25 January 2018 External T.I. 2017-0709241E5- Subsections 125(3.2) & 125(5.1)-- summary under Subsection 125(5.1) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(5.1) business limit is ground first based on taxable capital before it can be assigned Does the assignment of the business limit under s. 125(3.2) occur before or after the business limit reduction in s. 125(5.1)? After noting that under s. 125(5.1) “the business limit … is reduced on a straight-line basis if the total of the taxable capital of the CCPC (employed in Canada) and, if applicable, of [associated] corporations … exceeds $10 million … [so that] once the taxable capital … reaches $15 million its business limit would be zero,” CRA stated:. ...

29 September 2020 External T.I. 2018-0757501E5 F- Crédit pour intérêts sur les prêts étudiants-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt capitalization of interest on a novation under Quebec law would constitute its payment A Quebec post-secondary student loan program provided for an initial 12-month “full exemption period” (in which the Quebec government paid the interest charged on the loan by the lender) and a subsequent six-month “partial exemption period” (during which the student borrower was required to pay interest on the loan balance). ... In addressing whether such capitalized interest qualified as being “paid” under a “loan made” under the Quebec financial assistance program so as to generate a credit under s. 118.62, CRA stated: By virtue of the Civil Code of Quebec, there can be payment where there is a handing over of money [(“tradition d’argent”)] between the debtor and the creditor or where there is novation by change of debt. … The mere addition of accrued interest to the principal amount of an original debt is generally not sufficient in itself to constitute a payment of such interest. If … the addition of interest to the principal … qualifies as a novation … the amount of interest will be considered paid when the novation occurs and will be eligible for the credit by virtue of section 118.62, if all the conditions set out in that section are otherwise satisfied. ...

REAL PROPERTY INTEREST & FTC (5638-2)-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 FTC for U.S. ... Income Tax Convention …, the U.S. has the right to tax Mr. A's gains on the disposition of his Canco's shares, as described … above. ... As a result … Mr. A would qualify to claim a foreign tax credit under subsection 126(1) … in respect of [such] U.S. tax liability…. ...

This would be the case as long as the support claim is bona fide and … with a reasonable chance of success, and even if the claim for support is unsuccessful …. Conversely, where an individual starts a support claim for the purpose of collecting a lump-sum payment that does not qualify as a support amount …, the individual is not entitled to deduct legal and accounting fees incurred for that purpose. Assuming that the support claim … was started to establish or collect support amounts … no adjustments to the individual’s prior years’ tax returns would be warranted to exclude the legal expenses previously deducted in computing the individual’s income. ...

15 June 1992 T.I. 921368 (December 1992 Access Letter, p. 18, ¶C56-208)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt No payment will be considered to occur pursuant to an agreement between the parties to the effect that interest on a promissory note will be deemed to be paid and then loaned back to the borrower. ...

(Tax Window, No. 24, p. 8, ¶2184)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A direct payment by a non-resident to Revenue Canada of a tax liability of a related Canadian corporation would entail the receipt of an amount by the Canadian corporation for purposes of s. 12(1)(x). ...

7 August 1992 T.I. 921752 (May 1993 Access Letter, p. 198, ¶C76-066)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Because the function of a journal entry is to record a transaction rather than to make it legally effective, the reclassification of a shareholder's loan into remuneration payable by a journal entry would not be considered to be payment of the remuneration. ...

18 February 1999 External T.I. 9825635- VALIDITY OF 104(5.3) ELECTION-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The comments in IT-378R, that the validity of an election may not be denied by a taxpayer once it is accepted by the Department, is applicable to other elections. ...

5 July 1990 TI AC59710-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Where a promissory note is given in consideration for services, the acceptance of the note would be considered to be an amount received under s. 12(1)(a) where the note has been accepted as absolute payment for the services, whereas if the note has been accepted as conditional payment, s. 12(1)(a) will apply only when actual payments are made on the note assuming the related services have not yet been performed at that time. ...

13 June 2012 External T.I. 2012-0435351E5 F-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt issuance of cheque not payment Cheques issued by Opco but not yet cashed would not reduce its cash on hand given that under the applicable law (the Quebec Civil Code), the issuance of a cheque does not constitute payment, so that the debt is not settled until the cheque is honoured. ...