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A as to 9% and 91% of the common shares, respectively) if she also wholly-owned Bco (a related corporation to Aco) – but not if she did not own any shares of a corporation related to Aco. ...

CRA indicated this is not required under the Act, but invoices remain proof of income tax liability thereunder – and, in this regard, referred to various statements in IC-78-10R4 regarding record retention. ...

16 February 2007 External T.I. 2006-0200541E5 F- Prestation universelle pour la garde d'enfants-- summary under Subsection 74.1(2) Summary Under Tax Topics- Income Tax Act- Section 74.1- Subsection 74.1(2) UCCB benefit put into separate bank account for child subject to attribution Regarding payments of the universal child care benefit (UCCB) paid into a separate bank account held for the child, CRA stated: [T]he interest income generated annually by the deposit of the UCCB and the Quebec refundable tax credit for child support into your children's bank accounts will have to be included in your income pursuant to subsection 74.2(2) …. ...

15 February 2006 External T.I. 2005-0126831E5 F- 120.4(1)- définition: montant exclu-- summary under Subsection 248(5) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(5) phrase “substituted property” must be used to engage s. 248(5) In finding that income from shares acquired by a minor child from money received as a consequence of the death of a parent was not excluded under s. 120.4(1) – excluded amount- para. ...

29 January 2018 External T.I. 2017-0682301E5- Deemed Distribution and Withdrawal from IRA-- summary under Subsection 56(12) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(12) deemed ITA inclusion on deemed distribution from IRA on renouncing U.S. citizenship or relinquishing green card 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. ...

13 February 1997 External T.I. 9701235- SUBSTANTIAL CANADIAN PRESENCE-- summary under Paragraph 206(1.1)(d) Summary Under Tax Topics- Income Tax Act- Section 206- Paragraph 206(1.1)(d) "The term 'services '... includes services performed under contract to or for the relevant corporation by an independent underwriting firm in the context of an offering of shares, warrants and/or debt of the relevant corporation to the public; the amount incurred for such services may include the commissions paid by the relevant corporation to the underwriters for their services rendered.... ...

31 March 1995 External T.I. 9501105- MORTGAGE RECEIVABLE- ACTIVE BUSINESS ASSET-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation "... ...

9 June 1995 External T.I. 9511455- CONTINGENCIES AND RESERVES SALE OF A BUSINESS-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A "... ...

15 April 2003 External T.I. 2002-0139305 F- Immigration-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) FTC can be generated where recapture of depreciation, and denied capital loss, are realized on a US rental building CCRA indicated that where a taxpayer disposed of a ½ co-ownership interest in a US rental building whose ACB but not its capital cost had been stepped up under former s. 48(3), so that a capital loss was realized which was denied under s. 39(1)(b) and recapture of depreciation was realized, a foreign tax credit could be computed under s. 126(1) based on the amount of the recapture. ...

After noting that “subsection 8(5) … provides that professional or malpractice liability insurance that is necessary to maintain a professional status recognized by statute is deductible in computing employment income,” CCRA went on to indicate that this provision did not authorize the deduction of the uninsured loss. ...