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9 May 2007 External T.I. 2006-0205741E5- partition of property-- summary under Paragraph 248(21)(c)) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(21)- Paragraph 248(21)(c)) s. 248(21) could apply to a subdivision and partition of a portion of a parcel followed by a subdivision and partition of the remaining parcel Three equal co-owners of a single parcel subdivide a portion of that original parcel into 150 lots and then partition so that each is the sole owner of 50 lots (while continuing to hold the remaining portion of the original parcel as co-owners – then subsequently, subdivide that remaining parcel into 120 lots and partition so that each becomes the sole owner of 40 lots. ...

11 May 2007 External T.I. 2006-0214351E5 F- Transfert d'un droit de propriété-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property an occupied unit in a co-owned duplex can be designated as a principal residence CRA applied the statement in IT-120R6, para. 3, that a unit in a duplex is a property that can be designated as a taxpayer's principal residence, to find that where a duplex is co-owned by a husband and wife, the one unit occupied by them can be designated as their principal residence – but when their daughter moves into the 2 nd unit (until then, a rental unit) and acquires a co-ownership interest in the whole property, they will be able to designate either of the two units as their principal residence, but not both. ...

Consequently, if all the conditions for designating a property as a principal residence are satisfied … only the number of years the taxpayer ordinarily inhabited the residence, excluding the years the land was vacant, could be included in the description of B in the formula in paragraph 40(2)(b). ...

Furthermore, with respect to subparagraph (d)(i) of the definition of "mineral" in subsection 248(1) … experts from the Ministry of Natural Resources have advised us that the degree of metamorphism that the primary rock has undergone is unlikely to have completely erased the stratification of the deposit. ...

CRA indicated that s. 248(30) was enacted only to deal with the issue that “the common law considers that there is no gift where the donor receives an advantage or consideration in return for the property transferred,” and that s. 24 8(30) “has no impact … [on] what constitutes a gift in civil law” (and also indicated that a donative intent was required under both private law systems). ...

Accordingly … Opco is not a bankrupt corporation for the purposes of subsection 128(1). ...

After finding that s. 115(2)(c) did not apply to deem the employment after the departure to be exercised in Canada, CRA stated: Consequently … if the non-resident person does not perform any of the employee’s employment duties in Canada, there would be no withholding tax with respect to the federal tax. ...

(c)(i) of the definition of "qualified small business corporation share," CRA stated: [P]ursuant to subparagraph 110.6(1)(c)(i) of the definition of QSBC, [CRA] is of the view that the phrase "attributable to assets used principally in an active business carried on … by the corporation" should be interpreted to refer to the fair market value of assets owned by the corporation. ...

. … [T]he term transport business does not include a transportation service that is incidental, where the services offered are offered as part of a whole. ...

8 November 2006 External T.I. 2006-0176171E5 F- Revente d'un bien amortissable- alinéa 13(7)e)-- summary under Subparagraph 39(1)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(b)- Subparagraph 39(1)(b)(i) capital loss denied on sale of building – proceeds reflected in UCC reduction Corporation A sold a building with a cost of $3,800,000 to an associated corporation (Corporation B) for its FMV of $4,200,000, so that s. 13(7)(e) reduced its cost to Corporation B to $4,000,000. ...