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16 March 2015 Internal T.I. 2013-0479861I7- Section 116 & forfeited deposits on real property-- summary under Subsection 248(4) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(4) forfeited sale deposit was proceeds of security interest rather than of tcp A non-resident vendor received a deposit under an agreement for sale of B.C. real property, which will be forfeited to it due to failure of the purchaser to close. ... CRA first stated (based on the s. 248(1) – "disposition" definition) that "there is a disposition of a right under a contract where an agreement of sale has been cancelled and the buyer's deposit is forfeited to the vendor," and noted that under s. 248(4) "where the property is a security interest derived by an agreement for sale, it is excluded from being an interest in real property and is thereby excluded from the definition of taxable Canadian property. ...

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution-- summary under Subsection 93(2.01) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(2.01) contribution of shares to a subsidiary caused the subsidiary shares to be substituted property CRA considered that the s. 93(2.01) stop loss rule applied where Canco made a contribution of capital to a foreign subsidiary (FA2) of its shares of a non-resident Finco subsidiary (FA1) which had paid dividends out of its deemed active business income to Canco – so that s. 93(2.01) denied a subsequent capital loss realized on an arm’s length sale of the FA2 shares to the extent of such dividends. ...

3 May 2016 CALU Roundtable Q. 5, 2016-0632641C6- Clearance certificate & GRE rules-- summary under Subsection 159(2) Summary Under Tax Topics- Income Tax Act- Section 159- Subsection 159(2) CRA will issue a clearance certificate for a partial estate distribution While a graduated rate estate may allocate a charitable donation tax credit within 60 months from the individual’s date of death in cases where GRE status is lost solely because of the expiry of the 36-month period, the gift nonetheless may need to be made within 36 months of death. ... CRA responded: The overall process to receive a clearance certificate is currently under review. … One avenue that can be pursued by legal representatives is the request of a clearance certificate for partial distribution. ...

7 July 2016 External T.I. 2015-0595481E5- Ontario Corporate Minimum Tax – Forgiven Debt-- summary under Clause 54(2)(b) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Taxation Act 2007- Section 54- Subsection 54(2)- Clause 54(2)(b) forgiven amount included in adjusted net income A corporation has a forgiven amount which it applies federally under the s. 80 rules but results in net income for financial statement purposes, causing a Corporate Minimum Tax liability under the Taxation Act, 2007 (“TA”). ... Therefore, if GAAP determines that an economic gain arising on a forgiven amount is to be included in a corporation’s net income or net loss, then the forgiven amount will also be included in [adjusted net income or net loss] for purposes of subsection 54(2) of the TA. … Further additions or deductions (“adjustment(s)”) to ANI/ANL are permitted if prescribed in section 9 of Regulation 37/09 of the TA. ...

7 October 2016 APFF Roundtable Q. 9, 2016-0652921C6 F- Résidence- actif utilisé / Residence- asset used-- summary under Qualified Small Business Corporation Share Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share farm house must be more than 50% used by farm employees to qualify Mr. ... [A] residence owned by a corporation will be regarded as used principally in the course of carrying on the business of farming if more than 50% of its use is as accommodation for persons who are actively employed in the farming business or their dependants. … Furthermore, the residence must be provided to the persons in their capacity as employees rather than as shareholders and the residence must be part of the business operation in that it provides accommodation for employees whose services may be required at virtually any time by virtue of the nature of the farming operations. ...

30 March 2011 External T.I. 2010-0390591E5 F- Cotisation spéciale-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amounts paid by set-off are both paid even though no movement of funds All the condo owners in a condo complex that was used only in a high-end commercial accommodation business leased their units to a manager for a share equalling 50% of the aggregate rental income (but with the municipal taxes and condominium fees for common services continuing to be borne by the co-owners directly). ...

11 May 2010 External T.I. 2009-0339151E5 F- Paragraphe 44.1- " actions de remplacement-- summary under Replacement Share Summary Under Tax Topics- Income Tax Act- Section 44.1- Subsection 44.1(1)- Replacement Share replacement share not required to continue to be of an eligible small business corporation after its issue Must a "replacement share" continue to be a share of an eligible small business corporation after its issue in order for the capital gain deferral under s. 44.1 to continue to apply? ... Therefore, regardless of whether a corporation's status changed after the time of issuance of the eligible small business corporation share, the effect of subsection 44.1 remains. … Thus, the deferred gain, which results in a reduction in the adjusted cost base, will be realized when the taxpayer sells the replacement shares, to the extent that the proceeds of disposition exceed the adjusted cost base. ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Paragraph 95(3)(d) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(3)- Paragraph 95(3)(d) R&D services of CFAs not part of M&P process Four U.S. ... We note that for purposes of the manufacturing and processing profits deductions set out in subsection 125.1(1), the expression qualifying activities (as defined in section 5202 of the Regulations) includes scientific research and experimental development (as defined in section 2900 of the Regulations) carried on in Canada. … [N]o such extended meaning applies for the purposes of paragraph 95(3)(d). ...

6 November 2003 External T.I. 2003-0039525 F- Canadian Renewable & Conservation Expenses-- summary under Paragraph 12(o) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 12- Paragraph 12(o) applications software used by computers for operation of biogas landfill site would be Class 43.1 or Class 12 property A Canadian renewable and conservation expenses (CRCE) project uses landfill sites, which are injected with bacteria to produce recoverable gas. ... CCRA responded: [S]ubparagraph (d)(viii) of Class 43.1 … specifically excludes property otherwise included in Class 10. ...

4 October 2002 Internal T.I. 2001-010564A F- PENSION ALIMENTAIRE-ARRERAGES-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt set-off does not constitute payment unless the parties so agree After finding that a lump-sum payment to cover support-payment arrears could be considered as an amount payable on a periodic basis, even though it was less than the amount initially anticipated, the Directorate went on to note: The Court of Appeal judge decided to credit the amount of $XXXXXXXXXX, which consisted of expenses incurred by Monsieur for the benefit of the child, against the balance of the arrears owed to Madame by Monsieur. ...