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5 December 2022 External T.I. 2021-0915921E5- ELHT – Class of beneficiaries-- summary under Class of Beneficiaries Summary Under Tax Topics- Income Tax Act- Section 144.1- Subsection 144.1(1)- Class of Beneficiaries employees of a class can have the same rights even if their benefit entitlements differ In order to qualify as an employee life and health trust (ELHT), s. 144.1(2)(e)(i) or (ii) must be satisfied. The test in s. 144.1(2)(e)(i)(A) requires that the “trust … contains at least one class of beneficiaries where the members of the class represent at least 25% of all of the beneficiaries of the trust who are employees of the participating employers under the trust.” ...

16 June 2017 External T.I. 2017-0698181E5- New principal residence rules & trusts-- summary under Subsection 40(6.1) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(6.1) s. 40(6.1) protected trust gain that accrued up to December 31, 2016 The estate of Deceased Parent, that qualified as a graduated rate estate (GRE) with a fiscal period of July 1, 2016 to June 30, 2017, sold the principal residence of the Deceased Parent in 2017 during that fiscal period at a gain. ... …[T]he transitional relief offered by proposed subsection 40(6.1) would be applicable in the scenario presented to any portion of the … gain that accrued up to December 31, 2016. ...

5 December 2022 External T.I. 2021-0915921E5- ELHT – Class of beneficiaries-- summary under Subparagraph 144.1(2)(e)(i) Summary Under Tax Topics- Income Tax Act- Section 144.1- Subsection 144.1(2)- Subparagraph 144.1(2)(e)(i) employee beneficiaries of a mooted EHLT form a single class if their benefit entitlements are reasonably similar A corporation (“Corporation”) operating a Canadian retail chain, and the over-1,000 stores that owned it settled a health and welfare trust (the “Trust”) providing health benefits to employees ol the Corporation (representing 22% of all employees under the Trust) and employees of Member stores and affiliates as to the balance. ... CRA responded: The term “class of beneficiaries” is defined in subsection 144.1(1) of the Act (for purposes of section 144.1 of the Act) as a group of beneficiaries with identical rights or interests under the trust. … [A] “right”, as it pertains to an ELHT, includes an entitlement to designated employee benefits (“DEBs”). ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) the forgivable loan portion of a CEBA loan is a s. 12(1)(x)(iv) receipt The Canada Emergency Business Account (“CEBA”) provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... This is also the case where the taxpayer made a subsection 12(2.2) election to reduce the paragraph 12(1)(x) inclusion in the year of receipt. … ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Gross Revenue Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Gross Revenue Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146(5) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(5) The payment of administration or management fees by an annuitant will constitute the payment of a premium to the RRSP. ...

1993 External T.I. 9335545 F- Sub — 256(2) and T2144-- summary under Subsection 256(2) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(2) Re RC's requirements for acceptance of a late-filed Form T2144. ...

16 August 1995 External T.I. 9512405- VESSELS- PARTIAL DISPOSITION & 13(16) ELECTION-- summary under Subsection 13(16) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(16) A partial disposition of a vessel will qualify as a disposition of a vessel for purposes of s. 13(16). ...

7 March 1997 External T.I. 9704665- NASDAQ & OTC BULLETIN BOARD-- summary under Regulation 3201 Summary Under Tax Topics- Income Tax Regulations- Regulation 3201 The Over-the-Counter Bulletin Board market in the United States is not a prescribed stock exchange, notwithstanding the ownership of that market by the National Association of Securities Dealers, Inc. ...