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29 November 1991 Internal T.I. 912299 F- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d) Dear Sirs: Re:  Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes:-        will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act;-         will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act;-         will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and We confirm this understanding. Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes:-         will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act;-         will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act;-         will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and-         will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...

4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement Unedited CRA Tags 87(4), 87(8), 87(8.4), 87(8.5). ... XXXXXXXXXX 2025-105373 Yannick Roulier March 4, 2025 Dear XXXXXXXXXX: Re: DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement We are writing in reply to your email dated February 14, 2025, in which you suggested that a particular statement made in the Department of Finance’s explanatory notes seems to be inconsistent with a technical reading of the legislation. ...

8 May 2012 Roundtable, 2012-0435731C6- CALU CRA Roundtable – May 2012 – Question 5 Unedited CRA Tags ITR 8304(10), 8503(26) Principal Issues: 1. ... CALU CRA Roundtable – May 2012 Question 5 – Individual Pension Plans (IPPs) Background The 2011 federal budget contained two proposals that affect certain defined benefit IPPs. ... The IPP PSPA calculation is determined using the formula A – B. Variable A is the greater of two amounts, described in paragraphs (a) and (b) respectively. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election CRA Tags ITR 5901(2.2) S.79 of Bill C-48 ITR 5901(2.1) ITR 5901(2)(b) 95(1) foreign accrual property income Principal Issues: 1) Do the surplus pools of a given CFA have to be adjusted as a result of a FACL carryback against the TCG portion of the FAPI inclusion reported in a previous year? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2014-056081 FACL carryback – Surplus implications, PAS election & application of Bill C-48 transitional rules This is in reply to your correspondence of December 8, 2014, wherein you requested our assistance in respect of the surplus implications of a "foreign accrual capital loss" ("FACL") carryback in the context of a given set of facts. ... The relevant part of paragraph 79(2)(a) of Bill C-48 reads as follows, as modified to incorporate the relevant deadlines that would be applicable in the context of the facts submitted (see text underlined): (…) if the corporation (…) elect in writing under this paragraph in respect of all of their respective foreign affiliates and file the election with the Minister of National Revenue on or before the day that is the later of (…) the filing-due dates for their taxation years that include the day on which this Act receives royal assent [June 30, 2014] and the day that is one year after the day on which this Act receives royal assent [June 26, 2014], subsections 5901(2) to (2.2) of the Regulations, as enacted by subsection (1), apply to dividends paid after December 20, 2002 by all the respective foreign affiliates of the elector corporations (…) In the context of the present case, the election for the PAS election rules to apply to the 2010-Dividend would have to have been made on or before June 30, 2014. ...