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. … [O]ur position that subsections 15(2) and (2.1) may apply to situations involving partnerships is consistent with the tax policy underlying the application of those subsections. … … CRA … appealed the Tax Court of Canada's decision. ...

11 May 2005 Roundtable, 2005-0127081C6 F- États financiers- Impôt de la Partie I.3-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) GAAP refers to Canadian GAAP Where a Canadian public corporation prepares its financial statements in accordance with US GAAP, will this be accepted as GAAP under s. 181(3)(b): CRA responded: GAAP refers to the current accounting standards or principles established by the … CICA …. … Where the balance sheet is prepared in accordance with U.S. ...

CRA responded: [A]n employer of a taxpayer makes contributions to a life insurance company that fall within the definition of RCA, the life insurance company is a custodian as [so] defined …. … [H]owever … a payment made to acquire an interest in a life insurance policy is not a contribution within the definition of RCA. ...

CRA indicated: The definition of “Canadian resident partnership” … is not relevant for the application of [subpara. 2(f)] …. ... The CRA will in general consider that [subpara. 2(c)] … is satisfied even if a particular vendor is not directly involved in the negotiations for the sale of shares, when [the other conditions are satisfied]. … … T5013 forms … do … not constitute a return of income for the purpose of [subpara. 2(e)] …. ... Therefore, neither a partnership nor the partners of a partnership in situations such as described above may use the cost recovery method …. ...

3 July 2019 Internal T.I. 2019-0791521I7- Tuition tax credit- University outside Canada-- summary under Subparagraph 118.5(1)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 118.5- Subsection 118.5(1)- Paragraph 118.5(1)(b)- Subparagraph 118.5(1)(b)(i) CRA will follow Fortnum in “factually similar” situations In response to a request as to its interpretation of s. 118.5(1)(b) following Fortnum, CRA first noted that, regarding the attendance of the taxpayer in that case at a 10- week summer semester consisting of 11 courses each of one or two weeks’ duration, “the court applied the three consecutive week requirement to the summer semester as a whole, rather than to each individual course in the semester,” and then stated: Our interpretation of subparagraph 118.5(1)(b)(i) … as explained in paragraph 2.10 of … S1-F2-C2.. has generally not changed as a result of … Fortnum. … [T]his case was heard … under the Informal Procedure … [and] do[es] not have precedential value. ...

In this regard we cite … MDS Health … and … Haro Pacific …. ...

31 August 2005 External T.I. 2005-0114421E5 F- Frais de garde d'enfants-- summary under Child Care Expense Summary Under Tax Topics- Income Tax Act- Section 63- Subsection 63(3)- Child Care Expense fees for breach of contract can qualify but not educational fees CRA commented on whether the following categories of expenses incurred by parents at a childcare centre qualified as child care expense: fees paid for child care services yes additional fees paid for child care services generally yes – “fees for additional child care (where the parent picks up the child after official daycare hours) are child care expenses … provided they satisfy the other requirements of that section” outings outside the daycare no – “the purpose of those activities is not to look after the children in order to protect them and thus enable the parents to earn employment income … [but instead] is to ensure the development of the children's physical, social and artistic skills” classes and activities given at the daycare; no – “the primary purpose of those courses and activities is not to provide childcare but rather to promote the cultural, physical and artistic development of the children.” fees incurred for breach of contract generally, yes – “ 2003-0183697 … [indicated] that the phrase ‘an expense incurred...for the purpose of providing… child care services’ found in subsection 63(3) was broad enough to include expenses incurred for the breach of a contract. This conclusion is valid as long as these costs are the result of an undertaking required of the parents in order for the child care to be provided.” interest charges paid by parents who pay their bills late no – these are not “charges that are … paid to provide childcare but rather to compensate the childcare centre when a parent fails to make a payment by the agreed date” annual dues for parents wishing to be on daycare's Board no fees for sunscreen and insect repellent yes ...

CCRA responded: [T]he situation … is similar to … Grenier …. Consequently, subject to additional facts to the contrary, … the interest paid … could be deductible pursuant to paragraph 20(1)(c). ...

CRA responded: [P]ursuant to subparagraph 152(4)(b)(i), paragraph 152(6)(f.1) and subsection 152(4.01) … an assessment to take into account a foreign tax credit under subsection 126(2.21) of the Act in respect of foreign taxes paid is permitted only where the assessment is made within 3 years after the normal reassessment period. ... …The Minister is not obligated to reassess a return simply because a waiver is filed by a taxpayer for a particular taxation year …. [A] blanket waiver request without sufficient details of a transaction would likely not be considered valid. … … 2016-066042 … opined that if any of the circumstances to support the deduction under subsection 126(2.21) of the Act (e.g., disposition of the property and/or foreign taxes paid) are present within the statutory assessment period referred to in paragraph 152(4)(b) of the Act, it may be appropriate for the Minister to consider a taxpayer’s waiver request for the emigration year to allow the Minister sufficient time to review and process any potential reassessment for this deduction beyond the aforementioned reassessment period. ...

In addition, the CRA generally considers that the Purpose Tests [in ss. 55(2.1)(b)(i) and (ii)] could apply to a dividend paid by an operating company to its corporate shareholder in order to dispose of surplus assets for the purpose of the purification and subsequent sale of [its] shares … 2017-0724021C6 …. … [T]he payment of the Dividend and the Sale are part of the same series …. ... Consequently, subsection 55(2) should likely apply …. ...