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5 April 2018 Internal T.I. 2017-0728581I7- Ss 125(3.2) & 125(8) amending the business limit Unedited CRA Tags 125(1), 125(2), 125(3), 125(3.2) Principal Issues: Whether corporations can amend the assignment of the business limit under subsection 125(3.2) and the assignment of the specified partnership business limit under subsection 125(8). ... Godson 2017-072858 Subsection 125(3.2) and 125(8) – amending an assignment of the business limit We are writing in reply to your enquiry of October 20, 2017, requesting our response to questions from the CPA forum – Saskatchewan. ... Will this administrative position continue to apply with respect to an amended assignment of a partner’s specified partnership business limit / an amended assignment of the business limit by the “first corporation” to a “second corporation” that earned specified corporate income from the first corporation? ...

1 August 2013 Internal T.I. 2013-0484061I7- Alternative Minimum Tax- Health & Welfare Trusts CRA Tags 127.52(1) Principal Issues: Whether a HWT is permitted to deduct expenses in excess of gross trust income when determining adjusted taxable income for purposes of the AMT? ... August 1, 2013 Individual Returns Directorate Income Tax Rulings Directorate Assessment and Benefit Business and Employment Division Services Branch Tom Baltkois Attention: Ann Charron 2013-048406 Alternative Minimum Tax – Health & Welfare Trusts We are writing in response to your email dated March 27, 2013, in which you requested further clarification of the comments in our technical interpretation # 2004-009364, issued November 26, 2004. ...

14 August 2014 Internal T.I. 2013-0506691I7- Capital Losses- Health & Welfare Trusts CRA Tags 3(b) 127.52(1) 111(1.1)(a) Principal Issues: Whether a HWT is permitted to deduct net capital losses when computing taxable income under Division C and/or adjusted taxable income under Division E.1? ... August 14, 2014 Taxpayer Services Directorate Income Tax Rulings Directorate Taxpayer Services and Debt Business and Employment Division Management Branch Tom Baltkois Attention: Yves Thivierge 2013-050669 Capital Losses – Health & Welfare Trusts We are writing in response to your email dated September 27, 2013, in which you requested clarification as to whether health and welfare trusts ("HWTs") are permitted to incur capital losses and deduct net capital losses when computing taxable income under Division C and/or adjusted taxable income under Division E.1 of the Income Tax Act (the "Act"). ...

1 March 1996 Internal T.I. 9605017- INCOME OF CONTRACTS, GAAP & PART I.3 Unedited CRA Tags 181(1) 181(3) 181.2(3) 181.2(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Reasons FOR POSITION TAKEN: (1)Subsection 181(3) and previous positions (941653 & 951794). (2)Subsection 181(3). ... GAAP & THE BALANCE SHEET Paragraph 181(3)(b) provides that "...the amounts reflected in the balance sheet presented to the shareholders of the corporation...prepared in accordance with generally accepted accounting principles,... ...

9 May 1991 Internal T.I. 910789 F- Ontario Current Cost Adjustment and the Ontario R & D Superableness Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d), 127(11.1) Dear Sirs: Re:  Ontario Current Cost Adjustment and the Ontario R & D Superableness This is in reply to your letter of March 13, 1991 concerning the Ontario Current Cost Adjustment and the Ontario Research and Development Superableness.  ... It is your understanding that.      Revenue Canada does not intend to include amounts deducted under these programs in income for federal purposes under paragraph 12(1)(x) of the Income Tax Act (the "Act").      amounts deducted under these programs do not require the taxpayer to reduce its capital cost of depreciable property under subsection 13(7.1) of the Act;.       ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate Unedited CRA Tags 90(6); 90(8)(a); 90(14) Principal Issues: Whether the exception in 90(8)(a) would apply where the "creditor affiliate" is sold for cash consideration before the 2-year time limit? ... Chantal Tubie HEADQUARTERS Senior Technical Specialist Income Tax Rulings International and Large Business Directorate Directorate International Tax Division Sylvain Grégoire International Advisory Services Section (East) 344 Slater Street, 6th Floor, Minto Place Ottawa ON K1A 0L5 2016-064552 Upstream Loan Rules – Sale of Creditor Affiliate This is in reply to your correspondence of May 2, 2016, wherein you requested our comments as to whether a taxpayer resident in Canada would have an income inclusion pursuant to subsection 90(6) if it transfers the shares of a foreign affiliate to a non-arm’s length purchaser in a case where the foreign affiliate ceases to be a “creditor affiliate”, within the meaning of that subsection, before the expiration of the two year time limit referred to in paragraph 90(8)(a) and the upstream loan remains outstanding after that time limit. ... Facts For illustrative purposes, we will use the following assumed facts: • A non-resident corporation (Foreign Parent) owns all the issued and outstanding shares of a corporation resident in Canada (Canco) and another non-resident corporation (SisterCo). • Canco owns all the issued and outstanding shares of another non-resident corporation (FA). • In 2013, FA makes a loan to SisterCo. • Before the expiration of the two year time limit specified in paragraph 90(8)(a), Canco sells its shares of FA to Foreign Parent for cash consideration. • The loan remains outstanding for more than two years. ...

30 November 1995 Internal T.I. 9530440- M & P Unedited CRA Tags 125.1 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Revenue Canada Round Table TAX EXECUTIVE INSTITUTE November 1995 Question- XX MANUFACTURING & PROCESSING Company Y, a Canadian corporation, purchases assembled microcomputers from a Canadian supplier. ... Would such installation activity be considered as "manufacturing or processing" ("M & P") under section 125.1 of the Income Tax Act (the "Act")? ...

8 July 1991 Internal T.I. 911569 F- Non-resident Withholding Tax & GST Unedited CRA Tags 215(1) Dear Sirs: Re:  Non-Resident Withholding Tax & GST This is in reply to your letter of June 10, 1991 whereby you inquired whether the withholdings required under subsection 215(1) of the Canadian Income Tax Act on     24(1)    under Regulation 105 of the Canadian Income Tax Regulations on    24(1)       by your company should be made "before or after" the goods and services tax ("GST") imposed under Part IX of the Excise Tax Act, R.S.C. 1985, c. ...

13 October 2004 Internal T.I. 2004-0060441I7- Hedging Gains / Losses of Partnership Unedited CRA Tags 20(1)(v.1) Reg 1206(3) Reg 1210(3) Principal Issues: Whether gains / losses realized by a partnership from a hedging activity may qualify for inclusion in the determination of the adjusted resource profits of a member of the partnership. Position: Yes, provided the hedging relates to qualifying production of the partnership such that the gains / losses would be included in the adjusted resource profits of the partnership but only the extent of the members share of such profits. ... Cameron Christine Savage (613) 347-1361 Co-ordinator, Resource Industries Attention: Zul Ladak 2004-006044 Hedging Gains / Losses of Partnership We are writing in response to your query regarding our memorandum dated December 9, 2003, wherein we provided comments in regard to certain Oil & Gas Audit Issue Sheets (our file 2003-00297). ...

8 November 2022 Internal T.I. 2022-0942701I7- RCMP cadet training – service buyback Unedited CRA Tags 5, 6, 147.1(11), 8501(2), 8503(3)(a)(i) Principal Issues: In the circumstances, is the period of cadet training completed by an RCMP cadet eligible service for purposes of subparagraph 8503(3)(a)(i) of the Regulations? ... November 8, 2022 HEADQUARTERS HEADQUARTERS Registered Plans Directorate Income Tax Rulings Directorate Irina Schnitzer Attention: Jeff Boxer 2022-094270 Re: Royal Canadian Mounted Police (“RCMP”) Cadet Training – Eligible Service We are writing in response to your email dated July 5, 2022, wherein you requested our views on whether the period of cadet training completed by an RCMP cadet constitutes eligible service for purposes of subparagraph 8503(3)(a)(i) of the Income Tax Regulations (the “Regulations”). ... (footnote 1) In addition, in Dhillon v The Queen, 2002 DTC 2083 (“ Dhillon ”) the Tax Court of Canada concluded that in the circumstances presented at trial there was an employee/employer relationship between the RCMP cadet and the RCMP during the period of cadet training. ...