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29 November 1991 Internal T.I. 912299 F- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d) Dear Sirs: Re:  Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes:-        will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act;-         will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act;-         will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and We confirm this understanding. Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes:-         will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act;-         will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act;-         will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and-         will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...

4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement Unedited CRA Tags 87(4), 87(8), 87(8.4), 87(8.5). ... XXXXXXXXXX 2025-105373 Yannick Roulier March 4, 2025 Dear XXXXXXXXXX: Re: DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement We are writing in reply to your email dated February 14, 2025, in which you suggested that a particular statement made in the Department of Finance’s explanatory notes seems to be inconsistent with a technical reading of the legislation. ...

8 May 2012 Roundtable, 2012-0435731C6- CALU CRA Roundtable – May 2012 – Question 5 Unedited CRA Tags ITR 8304(10), 8503(26) Principal Issues: 1. ... CALU CRA Roundtable – May 2012 Question 5 – Individual Pension Plans (IPPs) Background The 2011 federal budget contained two proposals that affect certain defined benefit IPPs. ... The IPP PSPA calculation is determined using the formula A – B. Variable A is the greater of two amounts, described in paragraphs (a) and (b) respectively. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election CRA Tags ITR 5901(2.2) S.79 of Bill C-48 ITR 5901(2.1) ITR 5901(2)(b) 95(1) foreign accrual property income Principal Issues: 1) Do the surplus pools of a given CFA have to be adjusted as a result of a FACL carryback against the TCG portion of the FAPI inclusion reported in a previous year? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2014-056081 FACL carryback – Surplus implications, PAS election & application of Bill C-48 transitional rules This is in reply to your correspondence of December 8, 2014, wherein you requested our assistance in respect of the surplus implications of a "foreign accrual capital loss" ("FACL") carryback in the context of a given set of facts. ... The relevant part of paragraph 79(2)(a) of Bill C-48 reads as follows, as modified to incorporate the relevant deadlines that would be applicable in the context of the facts submitted (see text underlined): (…) if the corporation (…) elect in writing under this paragraph in respect of all of their respective foreign affiliates and file the election with the Minister of National Revenue on or before the day that is the later of (…) the filing-due dates for their taxation years that include the day on which this Act receives royal assent [June 30, 2014] and the day that is one year after the day on which this Act receives royal assent [June 26, 2014], subsections 5901(2) to (2.2) of the Regulations, as enacted by subsection (1), apply to dividends paid after December 20, 2002 by all the respective foreign affiliates of the elector corporations (…) In the context of the present case, the election for the PAS election rules to apply to the 2010-Dividend would have to have been made on or before June 30, 2014. ...

3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan Unedited CRA Tags 6(1)(a), 248(1) “private health services plan” Principal Issues: Whether a health spending account established for a sole employee-shareholder can qualify as a private health services plan. ... CALU Roundtable – May 2022 Question 10 – Private Health Services Plans Background An employer can offer its employees a Private Health Services Plan (PHSP) that takes the form of a Health Spending Account (HSA), also known as a cost-plus plan. ...

16 June 2014 STEP Roundtable, 2014-0526591C6- STEP CRA Roundtable – June 2014 – Question 9 CRA Tags 156 Principal Issues: Whether the CRA will continue with its practice of not assessing interest and penalties where an inter vivos trust does not make instalment payments as required under section 156. ... STEP CRA Roundtable – June 2014 QUESTION 9. Interest and Penalties on Deficient Instalments of Inter Vivos Trusts In response to question 20 at the 2010 STEP Canada National Conference, the CRA noted that under the current administrative policy, the CRA does not assess installment interest and penalties where an inter vivos trust does not make installment payments required under section 156. ...

22 September 1993 External T.I. 9304130- Direct ou indirectement — Fusion ou liquidation — Papillon Unedited CRA Tags 55(3)(b) SESSION SPÉCIALE DE L'APFF: 55(2) ET 55(3) DE LA LOI ETTRANSACTIONS PAPILLONSAPFF — 10 février 1993 Question 32 Il appert que Revenu Canada, Impôt a récemment donné une décision anticipée favorable lorsque dans le cadre d'une réorganisation papillon, la filiale de la corporation bénéficiaire du transfert est fusionnée plutôt que liquidée. ...

27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business Unedited CRA Tags 84(2), 120.4(1), 120.4(1.1), 125(7), 248(1) Principal Issues: Comparison of CRA’s response to question 7 of the 2018 STEP CRA Roundtable (2018-074403) and examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults. ... CRA Roundtable Question 10: TOSI – Excluded Shares and Related Business In question 7 of the 2018 CRA Roundtable of the Society of Trust and Estate Practitioners (“STEP”) the following question was asked: “Assume that a corporation has no business income because it derives income from property (possibly rental income from real property where the activities are not sufficient to constitute business income). ... Yet, even if it has been determined – taking into account the assumption made in Question 7 – that the shares of the capital stock of the corporation could not qualify as excluded shares, an amount received from this corporation by a specified individual would nevertheless be an excluded amount in respect of the specified individual. ...