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8 June 2018 Internal T.I. 2018-0744881I7- Regulation 403 – allocation of income-- summary under Subsection 403(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 403- Subsection 403(3) PE for 403(3) purposes includes any PE of any partnership of which insurer is member An insurance corporation (that reinsures policies issued by another insurer) holds partnership interests in several partnerships that have no insurance business and have permanent establishments in other provinces, but are not involved in an insurance business. ... Consequently … the taxpayer will have a PE in any province where the partnerships have a PE. … [B]ased on the fact that the taxpayer derives income (premiums) from reinsuring property situated in a province where the taxpayer has a PE due to being a member of a partnership, subsection 403(1) of the Regulations will allocate the taxpayer’s taxable income on a proportional basis to that province. … In view of the taxpayer having a PE in the province(s) where the partnerships have a PE, subsection 403(3) does not apply to the taxpayer with respect to those provinces. ...

15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) s. 39(2) application on USD pref redemption, cf. if USD common shares The redemption of U.S. ... However, the Directorate noted its previous comments that MacMillan Bloedel “ deals with the redemption of redeemable and retractable preferred shares, which may be viewed as similar to the repayment of a debt obligation” and it is “not prepared to extend the reasoning to a redemption of shares in general.” ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(4) to be improvements or alterations to leasehold interest, property acquisitions must be assimilated to landlord’s property The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ... Regarding whether the costs of such work should be added to the cost of the taxpayer’s Class 13 leasehold interest pursuant to Reg. 1102(4) before regard was had to Reg. 1102(5), CRA stated: [A]n amount expended is for the making of improvements or alterations to a leased property within the meaning of subsection 1102(4) where such expended amount relates to property that is incorporated into the leased property and becomes the property of the lessor. … Generally, the owner of a building owns everything that is joined to the building. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership leasehold improvements are assimilated to the landlord’s property unless the lease specifies otherwise Before quoting from Mount Robson in this regard, the Directorate indicated that: Generally, the owner of a building owns everything that is joined to the building. ...

A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration inter alia for annual royalties payable out of any oil & gas production. ... A carries on a business through a PE in Canada and the oil & gas royalties are attributable to the PE, Part XIII… of the Act does not apply, and the company is not required to withhold tax…. ... The company is required to… use the exemption code "S" …. Where neither paragraph 805(a) nor (b)… apply, the annual royalties paid to Mr. ...

23 January 2015 External T.I. 2013-0509771E5- Oil & gas payments made to U.S. resident-- summary under F Summary Under Tax Topics- Income Tax Act- Section 66.4- Subsection 66.4(5)- F FMV addition and subtraction where drilling rights are granted for royalty Mr. A, a U.S. resident, grants the right to drill for or take the oil & gas from his Canadian freehold property to a Canadian company, in consideration for an upfront bonus of $100,000, and annual royalties payable out of any oil & gas production. ... However, the proceeds of disposition (i.e., $100,000 + $300,000) of the CRP (i.e. the drilling etc. rights given to the Canadian company) were subtracted from his CCOGPE pool under variable F. ...

2 August 2013 External T.I. 2013-0475261E5- Eligible Dividend- Late Filing 89(14.1) & 184(3)-- summary under Subsection 89(14.1) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(14.1) A Canadian-controlled private corporation makes a s. 184(3) election to deem the excess portion of a capital dividend to be a separate taxable dividend. ... CRA indicated that it would accept a late designation request made within three years, to the extent of a GRIP balance to support an eligible dividend designation, provided the following conditions are met: * The taxpayers took reasonable steps and care to comply with the requirements in respect of subsection 83(2) and the computation of the capital dividend account at the time that the capital dividend election was originally made; * The late designation request under subsection 89(14.1) was not specifically intended by the taxpayers at the time that the subsection 83(2) election was made nor does the late designation request form part of a series of requests made on a regular basis; and, * The late designation request does not involve aggressive tax planning. ...

3 February 2005 External T.I. 2005-0111871E5 F- Intérêts / mise à part de l'argent-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) cash damming to pay current deductible business expenses is an eligible use which continues with the business Regarding the deductibility of interest on borrowed money used for current business expenses in a cash damming context, CRA stated: Where the borrowed money is used to pay a current expense that is incurred for the purpose of earning business income and is deductible … the test of a direct connection is satisfied in the year the expense is incurred and in subsequent years. … [I]nterest on borrowed money used to pay a current expense incurred to earn business income will continue to be deductible as long as the source of income, the business, does not disappear. However, the provisions of section 20.1 could, depending on the case, allow the interest to be deductible after the source of income has disappeared. … [T[he total value of the assets of the business is not a criterion for determining whether interest on borrowed money used to pay a current expense incurred to earn business income is deductible. ...

At the same time, they agreed that if a legal proceeding of the corporation to obtain damages to compensate for lost income resulted in the receipt of damages, he would receive a dividend on his preferred share that was a percentage of the damages – but that if the law suit was unsuccessful, he would agreed to reimburse the corporation for certain legal fees related to the litigation. ... Regarding whether the individual could deduct his reimbursement payment, CRA stated. … Mr. A's undertaking to reimburse the legal costs of the corporation only took effect if the corporation received an unfavourable decision …. ...

As a preliminary matter, CRA stated: Whether travel between Staff’s home and a particular location is personal will generally depend on whether the location is a RPE [regular place of employment]. … [F]or purposes of determining whether any particular location may be considered a RPE, we would generally consider an entire townhouse complex or apartment building to be one location. ... Staff, however, must remain available … during this downtime and may be redirected to another call out at any time during a standby shift. ... CRA stated: [T]o the extent that the location of the employee’s residence is also a place of business … of their employer, travel from such a location to another RPE would not be of a personal nature. ...