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2001 Ruling 2001-0077753- DIRECTORS FEES & STOCK OPTIONS-- summary under Paragraph 7(1)(a) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) options received on behalf of partnership Confirmation that where employees of the general manager of two partnerships sit on the board of directors of corporations on behalf of their employer, they are not required to report directors' fees and stock options paid to them as directors of the company. ...

1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS-- summary under Qualifying Home Summary Under Tax Topics- Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home Regarding the purchase of a unit that consisting of a leasehold interest in the property and a number of shares in the corporation that owns the property, CCRA noted that advance rulings had found that a unit consisting of a leasehold interest and shares, and giving its holder the right to the personal enjoyment of the housing unit would be a housing unit for the purposes of the definition of "principal residence", and that the acquisition of such a unit could qualify as a qualifying home for HBP purposes. ...

2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103-- summary under Paragraph 103(4)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) Where a retiring allowance of $30,000 was paid in 30 equal weekly payments of $1,000 to a Quebec employee, the Directorate determined that the rate of withholding would be determined under Reg. 102(1) on the basis of being periodic payments of $1,000 rather than pursuant to Reg. 103(4)(c)(i) as a lump sum payment over $15,000. ...

7 February 2000 External T.I. 2000-0000555- NURSING HOME FEES-FOOD & ACCOM.-- summary under Paragraph 118.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(b) "Generally, all regular fees charged by a nursing home, including any component for accommodation or meals, are normally accepted as being on account of full-time care in a nursing home. ...

19 March 2001 External T.I. 2001-0063345 F- RS & DE- MANDATAIRE-- summary under Clause 37(1)(a)(ii)(E) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1)- Paragraph 37(1)(a)- Subparagraph 37(1)(a)(ii)- Clause 37(1)(a)(ii)(E) organization did not qualify under s. 37(1)(a)(ii)(E) because it made disbursements only as agent The applicant did not qualify under s. 37(1)(a)(ii)(E) because it disbursed amounts to other entities only as agent for taxpayers and thus did not “carry on activities that consist of receiving amounts from taxpayers, other than as an agent of the taxpayers, and redistributing those amounts to the associations, institutions or corporations referred to in clauses 37(1)(a)(ii)(A) to (C).” ...

1999 Ruling 9903543- TOTAL RETURN SWAPS & MUTUAL FUND TRUST-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing An open-end unit trust invests the proceeds of a public offering in a note of a bank and then enters into a total-return swap with the Bank respecting a bond index (some of the components of which correspond to bonds held by the bank). ...

15 January 2021 External T.I. 2020-0847781E5- CEWS- remuneration / SSUC- rémunération-- summary under Eligible Remuneration Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Eligible Remuneration non-cash taxable benefits are not “eligible remuneration” An “eligible employee” of an eligible entity excludes an individual who is without remuneration by the eligible entity in respect of 14 or more consecutive days in a qualifying period ending before July 5, 2020. ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 4, 2020-0851621C6 F- RRSP or RRIF on death – Joint election-- summary under Subsection 146(8.1) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8.1) a specific bequest of a RRSP proceeds to a surviving spouse cannot be treated as a refund of premiums (a) Where an unmatured RRSP is the subject of a particular legacy to the deceased annuitant's spouse and the RRSP proceeds are distributed by the RRSP issuer directly to the surviving spouse, does the CRA require Form T2019 to be filed? ... Since the executor exercises the seisin of the legatee by particular title at the formation of the estate, in such a case, the amount paid under the deceased annuitant's RRSP is part of the annuitant’s estate, with the result that such an amount would not qualify as a "refund of premiums" within the meaning of subsection 146(1), even though the proceeds of the RRSP are paid by the issuer of the RRSP directly to the surviving spouse in accordance with the instructions of the executor. … Thus, as specified in subsection 146(8.1), the executor and the Spouse will have to file Form T2019 jointly if they wish to designate the amounts that the estate received (or, as the case may be, is considered to have received) from the deceased annuitant's RRSP as a refund of premiums received by the Spouse. ...

10 October 2024 APFF Roundtable Q. 11, 2024-1028921C6 F- Récupération d’amortissement liée à un bien de la catégorie 10.1 – travailleur autonome-- summary under Paragraph 13(7)(d) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(d) where a vehicle is used both personally and for business by a self-employed worker, there is a choice between a simplified method, and that under ss. 13(7)(c) and (d) CRA considers that the CCA deduction for the motor vehicle of a self-employed worker that is used for both business and personal use can be computed by determining the amount of CCA in respect of the motor vehicle as if it were used entirely for business purposes, while deducting annually only the proportion of CCA corresponding to the business use in the particular year. ... Since the cost to him of the passenger vehicle (a designated immediate expensing property per Reg. 1104(3.1)) was higher than the Reg. 7307(1) limit, s. 13(7)(i) provided that the proceeds of disposition were computed as: $38,000 X $34,000/ $50,000 = $25,840, resulting in recapture of depreciation. ...

8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6- Qualifying person & multiple shares-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A The correspondent noted that in Canada, if each class of shares of a public company with multiple classes must be considered separately for purposes of satisfying the de minimis or 10-percent tests in the U.S. tax regulations (treated as being applicable for Canadian purposes under para. 2(c) of the "qualifying person definition) very few Canadian corporations with multiple classes of voting shares will be considered "qualifying persons" for purposes of the LOB clause. ...