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22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) A lease obligation reflected as an asset on the balance sheet of a lessor corporation is not eligible for an investment allowance as a loan or advance. ...

Between Sub. 13(21.2) & 88(1) of ITA-- summary under Subsection 13(21.2) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21.2) Where a subsidiary corporation has had s. 13(21.2) apply to a transfer of depreciable property to its parent corporation, and the subsidiary is then wound up under s. 88(1), ss. 88(1)(e.2) and 87(2)(g.3) will deem the parent corporation to be a continuation of the subsidiary corporation for the purposes of applying the rules in s. 13(21.2) to the parent corporation in respect of the denied terminal loss. ...

29 March 2001 External T.I. 2001-0074145- Affiliated persons & stop loss rules-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) Where the shares of a corporation are owned equally by four trusts having the same corporate trustee, s. 40(3.6) will apply to deny a capital loss arising on the redemption of the shares of one of the trusts. ...

29 March 2001 External T.I. 2001-0074145- Affiliated persons & stop loss rules-- summary under Subsection 40(3.6) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.6) Where the shares of a corporation are owned equally by four trusts having the same corporate trustee, s. 40(3.6) will apply to deny a capital loss arising on the redemption of the shares of one of the trusts. ...

7 January 2003 External T.I. 2002-0133675- Cash Call Provisions & Contingent Rts-- summary under Paragraph 251(5)(b) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) Ss.251(5)(b) and 256(1.4) applied to a shareholders agreement that provided that where one of the shareholders failed to advance money to the company following an operating fund deficiency, the other shareholders could choose to advance the funds which the defaulting shareholder had failed to advance, in which event the defaulting shareholder would have its equity diluted. ...

8 November 1999 External T.I. 9914135- INTEREST & PENALTY RE MICHIGAN SBT-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose Penalties in respect of the Michigan single business tax do not meet all the conditions specified in IT-104R2, para. 3 and therefore, unless the facts show otherwise, are not deductible. ...

23 March 2021 TEI Roundtable, 2021-0879631C6- CERS- Net Leases, Qualifying Revenue & Deadlines-- summary under Subsection 125.7(2.1) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(2.1) table of filing deadlines What are the deadlines to file an application for the CEWS and the CERS? ...

1 March 2001 External T.I. 2000-0050275 F- Remboursement de prime / enfant infirme-- summary under Subsection 146(8.1) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8.1) overview or rules for transfer of taxpayer’s RRSP on death to financially dependent child Regarding whether the taxpayer’s RRSP could be transferred upon death to the taxpayer’s daughter free of tax, CCRA discussed the rules under ss. 146(8.9) and (8.1) for the transfer to a financially dependent child. ...

1 February 2001 External T.I. 2000-0041535 F- Actionnaire rattaché / droit de 1er refus-- summary under Paragraph 4901(2.2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 4901- Subsection 4901(2.2)- Paragraph 4901(2.2)(b) comments in IT-419R, para. 13 re shotgun clauses etc. are applicable to Reg. 4901(2.2)(b) CCRA confirmed that the comments in IT-419R, para. 13, regarding the scope of the contingent right to acquire shares also applied to the interpretation of Reg. 4901(2.2)(b). ...

2006 Ruling 2005-0151001R3- Prescribed Shares / plan of arrangement-- summary under Subsection 6204(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 6204- Subsection 6204(3) where pursuant to an arrangement agreement that is implemented under a plan of arrangement, employee stock options previously granted by the "Target" are transferred by the employees to Target in exchange for cash amounts equal to their in-the-money value before the acquisition pursuant to the agreement and plan by the purchaser of 100% of the shares of Target for cash consideration, such purchaser will not be a "specified person" at the time the options are so transferred. ...