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25 November 2021 CTF Roundtable Q. 4, 2021-0912111C6- Liable To Tax & Territorial Taxation-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a Singapore corporation was a resident there for Treaty purposes – even though it was subject to tax on a territorial basis- provided its CMC was there Generally, a person must be “liable to tax” in a contracting state to be a resident there for treaty purposes. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subparagraph 1102(5)(a)(iii) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(5)- Paragraph 1102(5)(a)- Subparagraph 1102(5)(a)(iii) rendering of an empty shell suitable for manufacturing constituted substantially changing its nature The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ... Although the Directorate agreed with the taxpayer that a property which otherwise was a Class 13 (leasehold) property (because at common law the improvements became part of the property of the landlord) could qualify as a Class 8 property (before then being potentially assimilated to Class 29), the Directorate went on to indicate that the above alterations to the Shells would be sufficient to deem the taxpayer’s leasehold interests to be a building or other structure, stating: Generally, alterations to a property do not materially change the nature of the property if, after the alterations, the use and size of the property remain the same. … Similarly, we are of the view that alterations to a property materially change its nature where the property has no particular purpose before the work is carried out but does have a particular purpose after the work is carried out. ...

5 December 2022 External T.I. 2021-0915921E5- ELHT – Class of beneficiaries-- summary under Subparagraph 144.1(2)(e)(i) Summary Under Tax Topics- Income Tax Act- Section 144.1- Subsection 144.1(2)- Subparagraph 144.1(2)(e)(i) employee beneficiaries of a mooted EHLT form a single class if their benefit entitlements are reasonably similar A corporation (“Corporation”) operating a Canadian retail chain, and the over-1,000 stores that owned it settled a health and welfare trust (the “Trust”) providing health benefits to employees ol the Corporation (representing 22% of all employees under the Trust) and employees of Member stores and affiliates as to the balance. ... CRA responded: The term “class of beneficiaries” is defined in subsection 144.1(1) of the Act (for purposes of section 144.1 of the Act) as a group of beneficiaries with identical rights or interests under the trust. … [A] “right”, as it pertains to an ELHT, includes an entitlement to designated employee benefits (“DEBs”). ...

6 September 2023 Internal T.I. 2019-0805481I7- Interaction of 17.1(1) & 247(2)-- summary under Subsection 17.1(1) Summary Under Tax Topics- Income Tax Act- Section 17.1- Subsection 17.1(1) interest can be imputed under s. 247(2) to a PLOI which already is subject to s. 17.1 imputed interest A corporation resident in Canada (“CRIC”) made various loans to an indirect wholly-owning parent which bore interest, payable at least annually, at a floating rate equal to the prescribed rate under Reg. 4301(b.1), with a timely joint election under s. 15(2.11) being made by them for each of those loans to qualify as a “pertinent loan or indebtedness” for the purposes of ss. 15(2) and 17.1(1). ... In short … subsection 247(2), which was broadly worded to embody the arm’s length principle, was meant to apply to all cross-border transactions, arrangements or events, including financial transactions, between non-arm’s length persons or partnerships, unless a specific exclusion applies. ...

2018 Ruling 2018-0740931R3 F- deductibility of interest – convertible debentures-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on borrowed money used to pay a premium on the cash redemption of convertible debentures is deductible Proposed transactions ACo, a listed Canadian public company, whose outstanding convertible debentures (the “Debentures”) are about to mature, will borrow from a lender (BCo) under “Loan 3.” ... However, upon receiving the notices of redemption for the Debentures, ACo will have the right to redeem such Debentures for an amount corresponding to the market value of the ACo shares into which they are convertible – which it will do, using proceeds of Loan 3 and thereby paying a “Conversion Premium C” over the redeemed Debentures’ principal amount. ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) the forgivable loan portion of a CEBA loan is a s. 12(1)(x)(iv) receipt The Canada Emergency Business Account (“CEBA”) provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... This is also the case where the taxpayer made a subsection 12(2.2) election to reduce the paragraph 12(1)(x) inclusion in the year of receipt. … ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Gross Revenue Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Gross Revenue Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146(5) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(5) The payment of administration or management fees by an annuitant will constitute the payment of a premium to the RRSP. ...

1993 External T.I. 9335545 F- Sub — 256(2) and T2144-- summary under Subsection 256(2) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(2) Re RC's requirements for acceptance of a late-filed Form T2144. ...