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Bundle Date Translated severed letter Summaries under Summary descriptor 2019-04-10 2 April 2019 Internal T.I. 2016-0649821I7 F- Unclaimed superannuation or pension benefits Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(a)- Subparagraph 56(1)(a)(i) subsequent year’s payment of benefit to a previously-unidentified beneficiary is only income in that year as an “in lieu of” pension amount General Concepts- Payment & Receipt amount received in Year 2 in lieu of pension benefit includes source deductions in Year 1 2012-03-30 12 March 2012 External T.I. 2011-0425361E5 F- Assistance paid by franchisor Income Tax Act- Section 9- Exempt Receipts/Business reimbursements of business expenses increase income Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) contest awards paid to franchisees includible under s. 12(1)(x) if not under s. 9 8 March 2012 External T.I. 2011-0426061E5 F- Bien agricole admissible Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(c) land that had been farmed for 5 years before being rented out to neighbouring farmer qualified, including farm house 21 March 2012 External T.I. 2011-0423141E5 F- Application du paragraphe 107(4.1) Income Tax Act- 101-110- Section 107- Subsection 107(4.1)- Paragraph 107(4.1)(c) s. 107(4.1) applied to distribution to settlor/beneficiary of property acquired with borrowed money 20 March 2012 External T.I. 2011-0424461E5 F- Déduction d'une rétribution à un agent immobilier Income Tax Act- Section 9- Timing commissions paid for leasing-up a new building generally are fully and currently deductible Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2012-03-23 28 February 2012 External T.I. 2011-0423201E5 F- Frais de déménagement Income Tax Act- Section 248- Subsection 248(1)- Eligible Relocation move following shift from part-time to ful-time at same employer did not qualify 29 February 2012 Internal T.I. 2011-0429701I7 F- Frais médicaux- services de tutorat Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(l.91) more particulars required re whether special needs tutor would qualify 2012-03-16 23 February 2012 External T.I. 2011-0421821E5 F- Test à l'alinéa 110.6(1)e) de la définition d'AAPE Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (e) replaced shares need not be owned for a period of 24 months prior to their replacement – but only for the portion of the 24 months before the time of disposition and ending at the replacement time 7 March 2012 External T.I. 2011-0421301E5 F- Bien agricole admissible Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Farm or Fishing Property- Paragraph (a) logging is not farming business if main focus is logging rather than growing, nurturing and harvesting trees Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(a) general discussion of s. 110.6(1.3)(a) tests 7 October 2011 Roundtable, 2011-0399411C6 F- Société de personnes- 103(1.1) Income Tax Act- 101-110- Section 103- Subsection 103(1.1) potential application of s. 103(1.1) where adult children form partnership with money gifted by parent and share pro rata to capital 7 March 2012 External T.I. 2011-0427551E5 F- Établissement stable Treaties- Income Tax Conventions- Article 5 presence of employee in Dominican Republic who did not habitually exercise general authority to contract did not constitute a PE ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-12-02 24 November 2011 External T.I. 2011-0416791E5 F- Shareholder Benefit Income Tax Act- Section 15- Subsection 15(1) payment by Opco of whole life insurance premiums on policy of which it is beneficiary, but sole shareholder is holder, generates s. 15 benefit – but not policy loan advance 21 November 2011 External T.I. 2011-0416881E5 F- Late-filed designation- paragraph 88(1)(d) Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(d) provided year of property disposition not-statute-barred, CRA generally will accept a late designation allocating s.88(1)(d) excess pro rata amongst the eligible properties 22 November 2011 External T.I. 2011-0420451E5 F- Canadian resource property Income Tax Act- Section 66.2- Subsection 66.2(5)- Canadian development expense- Paragraph (e) farm-in policy inapplicable where an option that might not be exercised: CDE addition as cash and exploration expenditures made 31 October 2011 External T.I. 2011-0422981E5 F- Whether property is eligible for a bump Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c)- Subparagraph 88(1)(c)(v) properties not bumpable as the subsidiary control was deemed by s. 88(1)(d.2) to be acquired at the same time as it acquired the properties Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c)- Subparagraph 88(1)(c)(vi) bump unavailable given previous non-arm's length acquisition Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(d.2) properties not bumpable as not owned at subsidiary's formation by related person 2011-11-25 7 October 2011 Roundtable, 2011-0411911C6 F- Exploitation entreprise par SP Income Tax Act- Section 96 Quebec partnership need not carry on business Income Tax Regulations- Regulation 2601- Subsection 2601(1) property income of partnership is taxable only to partner (as to its share) in its province of residence 7 October 2011 Roundtable, 2011-0411831C6 F- Définition du mot mois Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (b) individual required to have held shares for 24 months plus one day to and including day of the determination time Statutory Interpretation- Interpretation Act- Section 35 24-month period preceding time on Date X interpreted as extending back 24 months from the day before Date X ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-09-23 6 September 2011 External T.I. 2010-0389011E5 F- L'interprétation de " est en droit de recevoir" Income Tax Act- Section 13- Subsection 13(7.1) taxpayer is entitled to receive Quebec M&P credit at end of year in which the eligible expenditures were incurred 12 September 2011 External T.I. 2011-0397731E5 F- Crédit d'impôt pour frais médicaux Income Tax Regulations- Regulation 5700- Section 5700- Paragraph 5700(h) "hospital bed" does not extend to all types of adjustable beds Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) aquatherapy classes (or pain management courses) do not qualify if non-qualified payee 16 August 2011 Internal T.I. 2011-0401721I7 F- Loss Utilization Income Tax Act- Section 88- Subsection 88(1.1)- Paragraph 88(1.1)(e) factors in determining whether investments are held as a business Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) holding company whose only sources of income were inter-affiliate loan and subsidiary shares had losses from property rather than business 2011-09-16 6 September 2011 Internal T.I. 2011-0401191I7 F- Automobiles mises à la disposition des employés Income Tax Act- Section 6- Subsection 6(2) standby not computed for months in which automobiles in storage and unavailable for use 2 September 2011 Internal T.I. 2011-0419111I7 F- Programme de compensation du MESS Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(u) social assistance payments aggregating less than $500 not required to be included in income 31 August 2011 External T.I. 2011-0416541E5 F- Montant admis en déduction- REÉR Income Tax Act- Section 146- Subsection 146(5) if premium not claimed, deduction amount is nil 2011-09-09 31 August 2011 External T.I. 2011-0415891E5 F- Increase in stated capital, stock dividends-55(2) Income Tax Act- Section 248- Subsection 248(28) s. 248(28)(a) applied to reduce capital gain on disposition of preferred shares on which a capital gain had been realized under s. 55(2)(b) Income Tax Act- Section 55- Subsection 55(2)- Paragraph 55(2)(c) capital gain recognized under s. 55(2)(c) not recognized a second time on sale of the shares ...

These are additions to our set of 981 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¼ years of releases of Interpretations by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-06-24 15 June 2011 Internal T.I. 2011-0405501I7 F- Withholding- stock option benefits Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) withholding obligation extends to stock option benefits Income Tax Act- Section 153- Subsection 153(1.1) it is up to employer to find a solution for need to withhold from s. 7 benefits 8 October 2010 Roundtable, 2010-0371911C6 F- Biens dévolus au conjoint Income Tax Act- Section 70- Subsection 70(6) no rollover for bequested shares that had to be sold to satisfy estate debts 10 June 2011 Roundtable, 2011-0404621C6 F- Rectification order in Québec General Concepts- Rectification & Rescission CRA awaiting resolution of AES and Riopel cases 9 June 2011 Internal T.I. 2011-0396721I7 F- Déduction- habitants de régions éloignées Income Tax Act- 101-110- Section 110.7- Subsection 110.7(1) regular absences of 8 days on a 43-day cycle did not interrupt “residence” in zone 2011-06-17 9 June 2011 Internal T.I. 2011-0395001I7 F- Co-propriété indivise d'un duplex Income Tax Act- Section 54- Principal Residence- Paragraph (a) 2 equal co-owners of duplex could each claim the principal residence exemption for “their” unit General Concepts- Fair Market Value- Land although each 50% co-owner of a duplex has an undivided interest in the whole dwelling, the FMV of her interest relates exclusively to the housing unit occupied by her General Concepts- Ownership co-ownership interest is in the whole but valuation of the part occupied should reflect rights of exclusive possession 7 June 2011 Internal T.I. 2011-0397921I7 F- Financement inter-sociétés Income Tax Act- Section 15- Subsection 15(2.1) notwithstanding Gillette, a connected “person” may include a partnership Income Tax Act- Section 227- Subsection 227(6.1) refund of withholding tax on repayment of loan Income Tax Act- Section 80.4- Subsection 80.4(3)- Paragraph 80.4(3)(b) s. 80.4 would not apply to a s. 15(2) loan if it is not repaid ...

These are additions to our set of 1,005 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ½ years of releases of Interpretations by the Directorate. ...

These are additions to our set of 1,011 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ½ years of releases of Interpretations by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-05-06 13 April 2010 External T.I. 2010-0382791E5 F- Logement offert gratuitement à un pasteur Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) occupation of free housing after ceased to be pastor not taxable if not in exchange for services 2011-04-29 4 April 2011 External T.I. 2010-0388741E5 F- Société quittant le Canada Income Tax Act- Section 250- Subsection 250(5.1) no requirement to file Canadian returns following continuance 22 March 2011 Internal T.I. 2010-0387551I7 F- Dépenses- travailleur indépendant Income Tax Regulations- Schedules- Schedule II- Class 8- Paragrpah 8(i) erotic costumes used on website did not qualify Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h) expenses of costumes, breast implants and rejuvenation expenses of erotic website were non-deductible 2011-04-22 8 October 2010 Roundtable, 2010-0373201C6 F- Change of Control and Amalgamation Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(a) CRA will respect out-of-ordinary course transactions that logically occur between AOC and amalgamation as being effected by predecessor 2011-04-08 30 March 2011 External T.I. 2010-0390591E5 F- Cotisation spéciale Income Tax Act- Section 9- Timing amounts assessed against the taxpayer by co-owners not deductible until expended on or in the business Income Tax Act- Section 248- Subsection 248(16)- Paragraph 248(16)(a)- Subparagraph 248(16)(a)(i) addition for GST and subtraction for ITC General Concepts- Payment & Receipt amounts paid by set-off are both paid even though no movement of funds 8 October 2010 Roundtable, 2010-0373501C6 F- Al. 212(9)d) proposé- remboursement Income Tax Act- Section 212- Subsection 212(9)- Paragraph 212(9)(d) need for alteration of 2-year limitation in s. 227(5) in order to recover tax back to 2000 ...

These are additions to our set of 1,029 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¾ years of releases of Interpretations by the Directorate. ...