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2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) joint contribution of shares of FA to Netherlands co-op in consideration for credits to their respective membership accounts deemed to be for share consideration Ruling respecting the combined operation of s. 95(2)(c) (similar in this regard to s. 85.1(3)) and s. 93.2) on a joint contribution by the three foreign affiliate shareholders of a foreign affiliate of their respective shareholdings to a Dutch co-operative (with membership interests rather than share capital) in consideration for credits to their respective membership interest accounts. ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate-- summary under Subsection 90(6) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(6) inclusion not dependent of maintenance of creditor affiliate status Where a non-resident subsidiary (FA) of Canco has made a loan to a non-resident subsidiary (SisterCo) of Canco’s non-resident parent (Foreign Parent), CRA considers that it is irrelevant that FA has ceased to be a creditor affiliate of SisterCo two years later, as a result of the sale by Canco of FA to Foreign Parent, so that s. 90(6) could still apply to include the loan’s amount in Canco’ income. ...

7 October 2016 APFF Roundtable Q. 9, 2016-0652921C6 F- Résidence- actif utilisé / Residence- asset used-- summary under Share of the Capital Stock of a Family Farm or Fishing Corporation Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Share of the Capital Stock of a Family Farm or Fishing Corporation primary employee use qualifies farm house CRA will accept that a farm house is an active business asset for purposes of the definitions of “qualified small business corporation share,” “share of the capital stock of a family farm or fishing corporation” and "interest in a family farm or fishing partnership" if it is used more than 50% by farming employees who are providing their services in that capacity rather than as shareholder (or partner). ...

22 December 2016 External T.I. 2015-0608201E5 F- Capital distribution from trust & NR4-- summary under Subsection 212(11) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(11) capital distributions other than of capital dividends not subject to Part XIII tax Although s. 212(11) deems all trust capital distributions to a non-resident beneficiary to be income distributions for Part XIII purposes, s. 212(1)(c) only imposes Part XIII tax on s. 104(13) income and capital dividend distributions. ...

21 January 2009 External T.I. 2008-0266191E5 F- Part IV & Capital Gain Strip-- summary under Paragraph 186(1)(b) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1)- Paragraph 186(1)(b) 943963 Ontario followed CRA confirmed its position in 9711005 and indicated that its position in 9906255 was no longer valid because of the 943963 Ontario decision. ...

16 May 2018 IFA Roundtable Q. 9, 2018-0748151C6- T1134s & Country by Country Reporting-- summary under Subsection 233.4(4) Summary Under Tax Topics- Income Tax Act- Section 233.4- Subsection 233.4(4) comparison of T1134 and CbC reporting Although the mandated requirement is a Finance requirement, what is CRA’s perspective on whether there is a need for T1134 filing in addition to the mandated country-by-country reporting? ...

17 March 1997 Internal T.I. 9631007- INTERACTION OF 85(1) & 110.6(19)-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) The benefit of making an election under s. 110.6(19) in respect of an eligible capital property or a depreciable property effectively will be lost if the property is transferred on a rollover basis to a corporation. ...

20 October 1997 External T.I. 9715265- INTERACTION OF SUBSECTION 212(11) & PARAGRAPH 212(1)(C)-- summary under Subsection 212(11) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(11) "In our view, subsection 212(11) of the Act merely characterizes any amount paid or credited by a trust or estate as income of the trust or estate for the purposes of paragraph 212(1)(c) of the Act. ...

13 May 1998 External T.I. 9718325- 104(13.1) & 104(18)-- summary under Subsection 104(13.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13.1) "Subsection 104(13.1) permits a trust to deduct less than the full amount of its income payable to a beneficiary and thus choose to have that income taxed at the trust level rather than the beneficiary level.... ...

14 July 1994 Internal T.I. 9407377- NON-RESIDENT PARTNER & 216 ELECTION (7558-3)-- summary under Regulation 805 Summary Under Tax Topics- Income Tax Regulations- Regulation 805 If a partnership is determined to be carrying on business in Canada, there will be no Part XIII tax liability in respect of rent paid to the partnership on the presumption that a non-resident partner is considered to be carrying on business through a permanent establishment in Canada. ...