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In finding that the cost of the land could not be bumped under ss. 87(11)(b) and 88(1)(d) because it was depreciable property, CRA noted: … IT-481... [states], " If a taxpayer acquires land on which there is standing timber (for example, freehold timberlands), such property is a timber limit.” and “Unlike land on which is located a property which qualifies for inclusion in one of the classes in Schedule II of the Regulations, land which is acquired as a part of a timber limit is depreciable under Schedule VI of the Regulations and does not exist as a separate property for purposes of the Act.” ...

As such … NRCo would be carrying on business in Canada. … We are not aware of any exceptions to the requirement to file a T2 where the non-resident corporation has no profit from the business carried on in Canada. ...

. … [I]n other types of situations where property is used for commercial and residential activities and/or where the particular property is not zoned as being residential, no portion of a mortgage debt on such a property would be considered as being a debt secured by way of mortgage on a house or a housing project for the purpose of subsection 130.1(6) …. ...

CRA responded: Due to the expression “except such portion that is deductible by the EPSP under subsection 20(11) of the Act … as it appears in paragraph 144(8.1)(b) … an employee beneficiary of an EPSP is, effectively, restricted to a foreign tax credit of no more than 15% of the foreign non-business income (other than income from real or immovable property) allocated to them by the EPSP. ...

After affirming the 15% limitation in the case of non-realty income, CRA stated: [U]nlike paragraph 144(8.1)(b) … there is no provision of the Act which deems any portion of the foreign NBIT paid by an EPSP to have been paid by an employee beneficiary for the purposes of subsection 20(11) or 20(12) of the Act. Consequently, an employee beneficiary would not be entitled to a deduction under either subsection 20(11) or 20(12) …. ...

After affirming the 15% limitation in the case of foreign non-realty income, CRA stated: [U]nlike paragraph 144(8.1)(b) … there is no provision of the Act which deems any portion of the foreign NBIT paid by an EPSP to have been paid by an employee beneficiary for the purposes of subsection 20(11) or 20(12) of the Act. Consequently, an employee beneficiary would not be entitled to a deduction under either subsection 20(11) or 20(12) …. ...

29 January 2018 External T.I. 2017-0682301E5- Deemed Distribution and Withdrawal from IRA-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) deemed Code taxability of IRA on renouncing U.S. citizenship generally would generate an FTC to deemed Cdn-resident recipient Where a U.S. long-term resident relinquishes her green card (or a U.S. citizen renounced citizenship) after having become a Canadian resident, there would be a deemed taxable distribution to her of the amount in her IRA for Code purposes – which by virtue of ss. 56(1)(a)(i)(C.1) and 56(12) would be deemed to be included in her income at that time for ITA purposes as well. ... Therefore the U.S. tax paid would factor into the computation of a foreign tax credit under subsection 126(1), provided all the conditions of that subsection were otherwise satisfied. … ...

[S]ubsection 96(1) … applies to treat a partnership as a separate person for the purposes of computing the income of each partner …. ...

3 January 1997 External T.I. 9639365- REIMBURSEMENT OF RRSP ADMINISTRATION FEES-- summary under Premium Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(1)- Premium contribution to plan to fund admin fees is a premium The Department briefly stated: [W]here the annuitant makes a payment to his or her RRSP trust as a contribution under the trust to be applied for the purpose of providing the annuitant with a "retirement income" (as defined in subsection 146(1) of the Act) on maturity, the payment is considered a payment of a "premium" as defined in subsection 146(1) … unless it is a payment excluded in the conclusion to that definition. … [A]dministration or trustee fees can also be paid directly by the annuitant outside the trust and that there is no deduction for such payments made after March 5, 1996. ...

Where a third party reimburses the RRSP trust's expenses on the sale of the units, or off-sets the expense by transferring in new units of an equivalent value to the redemption fee, this would not be considered a contribution to the trust by the annuitant or a spouse …. Thus, the payment would not be considered a "premium" as defined in paragraph 146(1)(f) … and would not be deductible pursuant to subsection 146(5) of the Act. ...