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16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C) CRA Tags 94(3) Principal Issues: Can a non-resident trust that is subject to "new" subsection 94(3) deduct an amount under subsection 91(5) in respect of a FAPI inclusion resulting from the application of "old" clause 94(1)(c)(i)(C)? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2015-059849 91(5) Deduction – Non-Resident Trust Subject to “Old” Clause 94(1)(c)(i)(C) This letter is in reply to correspondence received from XXXXXXXXXX, an International Tax Auditor with the XXXXXXXXXX Tax Services Office, on July 14, 2015, wherein she requested our assistance in respect of the possible application of subsection 91(5) to a particular situation involving a non-resident trust. ... Comments The relevant portions of “old” subparagraph 94(1)(c)(i) read as follows: (i) the trust is deemed for the purposes of this Part and sections 233.3 and 233.4 to be a person resident in Canada no part of whose taxable income is exempt because of section 149 from tax under this Part and whose taxable income for the year is the amount, if any, by which the total of (…) (C) the amount, if any, by which the total of all amounts each of which is an amount required by subsection 91(1) or (3) to be included in computing its income for the year exceeds the total of all amounts each of which is an amount deducted by it for that year under subsection 91(2), (4) or (5), and Based on the wording of “old” clause 94(1)(c)(i)(C), the FAPI-Inclusions consist of net amounts of inclusion resulting from the application of subsections 91(1) or (3), and subsections 91(2), (4) or (5), as the case may be, in computing NRT’s income for its 2002, 2004 and 2006 taxation years. ...

12 January 2022 Internal T.I. 2021-0920371I7- METC – Cost of a cast Unedited CRA Tags Section: 118.2; paragraphs 118.2(2)(i) and (m), paragraph (i) of Regulation 5700 Principal Issues: Whether the cost of a walking cast would qualify as an eligible medical expense for the purposes of the METC. ... January 12, 2022 Marie-Pier Valiquette Income Tax Rulings Directorate A/Senior Programs Officer, Business and Employment Division Sales Tax and Benefits Information Cynthia Underhill Section, ABSB 2021-092037 Medical expense tax credit – eligibility of a walking cast We are writing in response to your email dated December 8, 2021, asking if the cost of a walking cast would qualify as a medical expense for purposes of the medical expense tax credit (“METC”), under section 118.2 of the Income Tax Act (Act). ... Section 5700 of the Regulations states: “[Prescribed device or equipment] — For the purposes of paragraph 118.2(2)(m) of the Act, a device or equipment is prescribed if it is a... ...

7 January 2009 Internal T.I. 2008-0304901I7- Taxation & Insolvency Unedited CRA Tags 164(1) Principal Issues: Whether all post-bankruptcy refunds vest automatically in a trustee in bankruptcy. ... Diegel & Feick Inc. (1980), 35 C.B.R. (N.S.) 309 (Ont. S.C.); Re Sihler (1982), 43 C.B.R. ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan CRA Tags 6(1)(f) 54 "capital property" 248(1) property 5(1) 6 39(1)(a)(iii) Principal Issues: 1. ... July 8, 2013 Trust Accounts Programs Division Income Tax Rulings Directorate Taxpayer Services and Debt Business and Employment Division Management Branch Kathryn McCarthy Attention: Marlene Sylvest 2012-047002 Settlement of Future Benefits – Administrative Services Only Plan We are writing in response to your e-mail of November 13, 2012, concerning an employer's group disability plan which is administered by an arm's length plan administrator ("administrator") on an administrative services only ("ASO") basis. ...

6 March 2015 Internal T.I. 2014-0553481I7- Taxable benefit – cell phones CRA Tags 6(1)(a) 6(1)(b) Principal Issues: Where an employer pays part of the cost of an employee's cell phone voice and data plan, whether the reimbursement is considered a taxable benefit for the employee under paragraph 6(1)(a). ... XXXXXXXXXX 2014-055348 March 6, 2015 Dear XXXXXXXXXX: Re: Taxable benefit – cell phones We are writing in response to your e-mail of October 21, 2014, and our conversations of January 6 (McCarthy/XXXXXXXXXX), and February 26, 2015 (McCarthy/XXXXXXXXXX), concerning the tax implications under the Income Tax Act ("Act") for certain employees of the XXXXXXXXXX ("Employer"), who use their personal cell phones to perform their employment duties. ...

7 August 2015 Internal T.I. 2015-0585011I7- Osteopaths & naturopaths in Quebec CRA Tags 118.4(2) Principal Issues: 1) Whether osteopaths and naturopaths are authorized medical practitioners in the province of Quebec for purposes of the federal medical expense tax credit (METC). 2) Whether Revenue Quebec's brochure entitled "Medical Expenses" can be relied on in determining whether a practitioner is an authorized medical practitioner for the purposes of the federal METC. ... Nadia Zinck Income Tax Rulings GST/HST/QST and Benefits Information Section Directorate Information Programs Division Randa El-Kadi Taxpayer Services Directorate (613) 670-9054 Assessment and Benefit Services Branch 2015-058501 Osteopaths and naturopaths in Quebec – Federal criteria for the medical expense tax credit Dear Ms. ...

3 March 2017 Internal T.I. 2016-0673661I7- Upstream loans – allocation of repayments Unedited CRA Tags 90(6); 90(8); 90(14) Principal Issues: Would the CRA follow the “first in, first out” method to allocate repayments in respect of multiple draws on a single credit facility? ... Marian Young HEADQUARTERS Senior International Auditor Income Tax Rulings International and Large Business Directorate Directorate International Tax Division Sylvain Grégoire International Advisory Services Section 2016-067366 Upstream loans – allocation of repayments This is in reply to your correspondence of October 26, 2016 in which you request our views on a particular aspect of the foreign affiliate upstream loan rules (the “Upstream Loan Rules”) contained in subsections 90(6) to (15). ...

24 October 1994 Internal T.I. 9420427- CAPITAL GAINS EXEMPTION & PERSONAL TRUSTS Unedited CRA Tags 110.6 104(21) 104(21.2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Holloway Attention: Madeleine Chiasson (613) 957-2104 942042 Capital Gains Exemption & Personal Trusts This is in reply to your memorandum of August 9, 1994, requesting the clarification of the operation of the draft legislation in respect of the elimination of the $100,000 lifetime capital gains exemption as of February 22, 1994. ...

13 May 2002 Internal T.I. 2002-0137727- MEALS & QUARTERS Unedited CRA Tags 6(6) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Vancouver Tax Services Office 613-957-8973 2002-013772 Taxability of Meals & Quarters Aboard a Ship in its Home Port We are writing in response to your inquiry of April 30, 2002, concerning a letter dated August 14, 1998 from the Canada Customs and Revenue Agency (CCRA) to the Department of Fisheries and Oceans (DFO) with respect to the above-noted issue. ...

10 May 2004 Internal T.I. 2004-0057511I7- NRH&WTrust:Barbados, Bermuda & Cayman Islands Unedited CRA Tags 75(3) Principal Issues: Does 75(3) apply to Non-Resident Health and Welfare Trusts located in specific jurisdictions? ... May 10, 2004 International Tax Directorate Pascal Tétrault 344 Slater Street, 6th Floor Ottawa, Ontario Attention: Linda Smith 2004-005751 Operation of 75(3) & Non-Resident Health and Welfare Trusts We are writing in response to your email of January 20, 2004 regarding the above captioned matter. ... It is also relevant to reproduce paragraph (a.1) of the definition "trust" in subsection 108(1), which reads: 108. (1) Definitions- In this subdivision, "trust" includes an inter vivos trust and a testamentary trust but in subsections 104(4), (5), (5.2), (12), (13.1), (13.2), (14) and (15) and sections 105 to 107 does not include [...] ...