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These are additions to our set of 1,838 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 1,849 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 1,859 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 1,890 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 1,898 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 1,907 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ½ years of releases of such items by the Directorate. ...

Repairs or Running Expense Belgega-finding that inducement paid to prospective emphyteuta (tenant) was capital expenditure- noted 9 June 2005 Internal T.I. 2005-0122511I7 F- Créance irrécouvrable dans une OSBL Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c)- Subparagraph 39(1)(c)(iv) loss on interest-bearing loan made by a director to an NPO qualified as BIL if NPO qualified as SBC Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(ii) a debt obligation bearing a reasonable rate of interest satisfies s. 40(2)(g)(ii) 9 June 2005 External T.I. 2004-0097451E5 F- Régimes d'assurances collectives Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) employees can potentially pay top-up amounts for further benefits or receive taxable compensation for opting for lower benefits Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) CRA criteria for determining whether there are 2 separate plans (one of which is fully employee-funded) 6 June 2005 External T.I. 2005-0114481E5 F- Division 149(1)o.2)(ii)(C) Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(B) deferred proceeds receivable for real estate sale do not qualify as real property Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(C) loan that funded rental property acquisition may still qualify after partial sale of portfolio/replacement borrowing can also qualify Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) loan that funded rental property acquisition may still qualify as “solely for the purpose of earning income” per s. 149(1)(o.2)(ii)(C) after partial sale of portfolio 9 June 2005 Internal T.I. 2005-0115481I7 F- Avantages imposables/voyages Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) since the particular shareholder-employees who benefited from trips provided by their employer’s supplier were known, the supplier should issue T4As to them Income Tax Regulations- Regulation 200- Subsection 200(2)- Paragraph 200(2)(g) T4As required to be issued to shareholder-employees of customers who were identifiable as receiving free trips – but not for sole proprietor customers 9 June 2005 Internal T.I. 2005-0117851I7 F- Choix du paragraphe 14(1.01) de la Loi Income Tax Act- Section 14- Subsection 14(1.01) taxpayer could not make s. 14(1.01) election where "exempt gains balance" in respect of his business for the year is not nil 7 June 2005 External T.I. 2005-0121551E5 F- Déduction des intérêts- co-emprunteurs Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed from spouse under line of credit for income-producing purpose is deductible ...

In Example 3, per “ Geransky and Kennedy, the sale of the capital assets in and of itself should not constitute a reorganization for the purposes of subsection 84(2) provided that R Co continues to carry on the same business.” ...

These are additions to our set of 1,977 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2005-04-01 23 March 2005 Internal T.I. 2005-0113931I7 F- Safe income on hand calculation: Life Insurance Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) non-deductible life insurance premiums reduced SIOH 2005-03-25 22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit Income Tax Act- Section 207.7- Subsection 207.7(2) where LC used to secure RCA benefits and refundable tax generated on funding of LC fees, refundable tax not recoverable based on paying the benefits Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax use of letter of credit to secure RCA benefits Income Tax Act- Section 207.5- Subsection 207.5(2) election not available to custodian holding an LC 22 March 2005 Internal T.I. 2005-0115451I7 F- Extinction d'une remise de dette Income Tax Act- Section 80- Subsection 80(1)- Forgiven Amount no deduction where forgiven debt is subsequently restored pursuant to improved fortunes clause Income Tax Act- Section 80.01- Subsection 80.01(10) repayment deduction under s. 80.01(10) General Concepts- Effective Date CRA assesses based on the state of affairs at year end 2005-03-18 1 February 2005 External T.I. 2004-0083921E5 F- Société mandataire, gain & CIÉ Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax US taxes paid by a corporation based on falsely representing that the related gain was its gain could generate a FTC to the Canadian shareholder for which it in fact was agent 4 February 2005 External T.I. 2004-0085361E5 F- Changement de résidence: émigration Income Tax Act- Section 122.6- Eligible Individual- Paragraph (c) required repayment of CCB if received after departure from Canada 31 January 2005 External T.I. 2004-0091301E5 F- Déductions à la source-avantage autre qu'en argent Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no source deductions required where a non-cash benefit is the sole remuneration Income Tax Act- Section 153- Subsection 153(1.1) no source deductions required where free accommodation was the intern's only benefit 4 February 2005 External T.I. 2004-0093611E5 F- Don par testament d'un bien culturel Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(a)- Subparagraph 39(1)(a)(i.1)- Clause 39(1)(a)(i.1)(B) s. 39(1)(a)(i.1) unavailable where capital gain realized under s. 104(4)follow-up in 2005-0131741E5 F 15 March 2005 Internal T.I. 2004-0108721I7 F- Don d'une licence Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts gift of a non-exclusive software licence was a gift of property Income Tax Act- Section 248- Subsection 248(1)- Property excepting WIP, definition of property is no broader than term’s ordinary meaning ...