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11 December 2024 External T.I. 2024-1039101E5 F- Vertical amalgamation & former paragraph 84.1(2)(e)-- summary under Paragraph 84.1(2)(e) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) s. 87(2)(j.6) continuity rule does not remediate the adverse consequences under the old intergenerational transfer rules of vertically amalgamating the subject corp S. 84.1(2.3)(a)(i), as part of the former (private-member bill) intergenerational business transfer rules, provided that if, otherwise than by reason of death, the children’s purchaser corporation disposed of the subject corporation shares within 60 months of their purchase, the exception in s. 84.1(2)(e) from the application of s. 84.1 was deemed never to have applied. 2022-0953991E5 F indicated that, consequently, if the purchaser corporation amalgamated, within the 60-month period, with the subject corporation, then the resulting disposition pursuant to s. 87(11)(a) by the purchaser of the subject shares would engage the s. 84.1(2.3)(a)(i) exclusion. ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) place of contract not primary determinant The Directorate agreed that the taxpayer, which was a Canadian manufacturer transferring some of its goods to a Japanese branch for sale there, was overstating its profits for purposes of s. 126(2), by treating most or all of the profits on the sale of such products as being profits of the Japanese branch. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) no pro-ration of FTC by s. 94 trust where Canadian gain was smaller than US gain A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Paragraph 94(3)(b) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(3)- Paragraph 94(3)(b) A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...

30 September 2013 Internal T.I. 2012-0439661I7- Income earmarked for future use & 95(2)(a)(i)-- summary under Subparagraph 95(2)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(i) funds earmarked for future projects of sister affiliates A CFA of Canco held funds generated from projects which were owned and operated by FA1, with the funds being "earmarked" for future investment in projects to be carried out by other CFAs of Canco. ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C)-- summary under Subsection 91(5) Summary Under Tax Topics- Income Tax Act- Section 91- Subsection 91(5) upward ACB adjustment to the CFA occurring as a result of recognized FAPI under the old s. 94(1) rules represented basis that could be distributed while the trust was subject to the new s. 94(3) trust rules A non-resident discretionary trust (“NRT”) owned all the shares of CFA. ...

28 September 2006 External T.I. 2006-0197841E5 F- Shareholders agreement & 256(1.4)-- summary under Paragraph 256(1.4)(a) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(1.4)- Paragraph 256(1.4)(a) s. 256(1.4) technically applies where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares Four unrelated individuals (A, B, C and D) each hold 25% of the shares (being common shares) of Opco through their respective wholly-owned holding companies (Aco, Bco, Cco and Dco). ...

17 January 2007 External T.I. 2005-0152601E5 F- Politique d'application RS & DE 1996-02-- summary under Paragraph 37(1)(a) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1)- Paragraph 37(1)(a) LGL and Tigney pro rata approach to in-Canada requirement What was the impact of the LGL decision (99 DTC 675, aff’d [2000] FCA No. 166) on Case C of Application Policy 1996-02- Testing and Studies Required to Meet Requirements in Regulated Industries, which read: The testing or engineering is performed in Canada to meet regulatory requirements, but the project is conducted outside Canada. ...

2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up-- summary under Paragraph 88(1.1)(b) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1.1)- Paragraph 88(1.1)(b) streamed losses of empty-shell Lossco flowed through on its dissolution as Lossco LP business had been acquired years earlier through sub LP Acquisition of Lossco business Subsequently to a CCAA filing by Lossco and members of its group, Taxpayer (a wholly-owned subsidiary of a Luxembourg company held by a group of (perhaps U.S.) investors), as limited partner, and its wholly-owned subsidiary, as GP, formed Lossco Business LP, which then acquired the business (the "Lossco Business”) of Lossco pursuant to the “Asset Sale Agreement”. ...

7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business royalty income from a music composing business is active business income Gagliese Productions found that royalty income of an author/musician was income from services because the person who derived the income was earning the income in the normal course of his business. ...