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Technical Interpretation - External
12 April 2023 External T.I. 2023-0960541E5 - FHSA - First-Time Home Buyer status
12 April 2023 External T.I. 2023-0960541E5- FHSA- First-Time Home Buyer status Unedited CRA Tags 146.6(1), 146.01(2)(a.1). ... XXXXXXXXXX 2023-096054 April 12, 2023 Dear XXXXXXXXXX: Re: First Home Savings Account This is in reply to email inquiry dated December 31, 2022 in which you asked us if your spouse will be eligible to open a First Home Savings Account (“FHSA”) on April 1, 2023. ... If you sell your home in 2023 and neither of you acquire or build a home, the earliest date that you or your spouse could open an FHSA is January 1, 2028. ...
Technical Interpretation - External
19 September 2023 External T.I. 2023-0971681E5 - Mineral Resource Certification
19 September 2023 External T.I. 2023-0971681E5- Mineral Resource Certification Unedited CRA Tags Definition of "mineral resource" in subsection 248(1) Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the lithium-bearing spodumene deposits of the taxpayer will be a principal mineral extracted from a non-bedded deposit. ... XXXXXXXXXX 2023-097168 André Payette September 19, 2023 Dear XXXXXXXXXX: Re: Mineral Resource Certification This is in response to your letter dated April 14, 2023, in which you requested on behalf of XXXXXXXXXX(“XXXXXXXXXX” or “the Company”) certification pursuant to subparagraph (d)(i) of the definition “mineral resource” in subsection 248(1) of the Income Tax Act (the “Act”) with respect to the lithium-bearing spodumene deposits (the “Deposits”) of its XXXXXXXXXX Project (the “Project”) located in the XXXXXXXXXX. ...
Technical Interpretation - External
24 August 2023 External T.I. 2023-0971691E5 - Mineral Resource Cert - XXXXXXXXXX Project
24 August 2023 External T.I. 2023-0971691E5- Mineral Resource Cert- XXXXXXXXXX Project Unedited CRA Tags Definition of "mineral resource" in subsection 248(1) Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the lithium-bearing spodumene deposits of the taxpayer will be a principal mineral extracted from a non-bedded deposit. ... XXXXXXXXXX 2023-097169 André Payette August 24, 2023 Dear XXXXXXXXXX: Re: XXXXXXXXXX Mineral Resource Certification This is in response to your letter dated April 14, 2023, in which you requested on behalf of XXXXXXXXXX or “the Company”) certification pursuant to subparagraph (d)(i) of the definition “mineral resource” in subsection 248(1) of the Income Tax Act (the “Act”) with respect to the lithium-bearing spodumene deposits (the “Deposits”) of its XXXXXXXXXX Project (the “Project”) located in XXXXXXXXXX. ...
Technical Interpretation - External
16 May 2023 External T.I. 2023-0967461E5 - Mineral Resource Cert – XXXXXXXXXX Project
16 May 2023 External T.I. 2023-0967461E5- Mineral Resource Cert – XXXXXXXXXX Project Unedited CRA Tags Definition of "mineral resource" in subsection 248(1) Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the lithium-bearing silicate spodumene deposits of the taxpayer will be a principal mineral extracted from a non-bedded deposit. ... XXXXXXXXXX 2023-096746 André Payette May 16, 2023 Dear XXXXXXXXXX: Re: XXXXXXXXXX Mineral Resource Certification This is in response to your letter dated March 15, 2023, in which you requested on behalf of XXXXXXXXXX certification pursuant to subparagraph (d)(i) of the definition “mineral resource” in subsection 248(1) of the Income Tax Act (the “Act”) with respect to the lithium-bearing silicate spodumene deposits (the “Deposits”) of its XXXXXXXXXX Project (the “Project”) located in XXXXXXXXXX. ...
Technical Interpretation - External
16 June 2023 External T.I. 2023-0967551E5 - Mineral Resource Cert - XXXXXXXXXX
16 June 2023 External T.I. 2023-0967551E5- Mineral Resource Cert- XXXXXXXXXX Unedited CRA Tags Definition of "mineral resource" in subsection 248(1) Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the lithium-bearing silicate spodumene deposits of the taxpayer will be a principal mineral extracted from a non-bedded deposit. ... XXXXXXXXXX 2023-096755 André Payette June 16, 2023 Dear XXXXXXXXXX: Re: XXXXXXXXXX. Mineral Resource Certification This is in response to your letter dated March 15, 2023, in which you requested on behalf of XXXXXXXXXX (the “Company”) certification pursuant to subparagraph (d)(i) of the definition “mineral resource” in subsection 248(1) of the Income Tax Act (the “Act”) with respect to the lithium silicate spodumene deposits (the “Deposits”) of its XXXXXXXXXX (the “Project”) located in XXXXXXXXXX. ...
Technical Interpretation - External
19 July 2023 External T.I. 2023-0970581E5 - Mineral Resource Cert - XXXXXXXXXX Project
19 July 2023 External T.I. 2023-0970581E5- Mineral Resource Cert- XXXXXXXXXX Project Unedited CRA Tags Definition of "mineral resource" in subsection 248(1) Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the lithium-bearing silicate spodumene deposits of the taxpayer will be a principal mineral extracted from a non-bedded deposit. ... XXXXXXXXXX 2023-097058 André Payette July 19, 2023 Dear XXXXXXXXXX: Re: XXXXXXXXXX. Mineral Resource Certification This is in response to your letter dated April 4, 2023, in which you requested on behalf of XXXXXXXXXX (“XXXXXXXXXX” or “the Company”) certification pursuant to subparagraph (d)(i) of the definition “mineral resource” in subsection 248(1) of the Income Tax Act (the “Act”) with respect to the lithium-bearing silicate spodumene deposits (the “Deposits”) of its XXXXXXXXXX Project (the “Project”) located in XXXXXXXXXX. ...
Technical Interpretation - External
23 May 2023 External T.I. 2023-0967231E5 - Mineral Resource Cert - XXXXXXXXXX Project
23 May 2023 External T.I. 2023-0967231E5- Mineral Resource Cert- XXXXXXXXXX Project Unedited CRA Tags Definition of "mineral resource" in subsection 248(1) Principal Issues: Whether NRCan can certify that the principal mineral to be extracted from the lithium-bearing silicate spodumene deposits of the taxpayer will be a principal mineral extracted from a non-bedded deposit. ... XXXXXXXXXX 2023-096723 André Payette May 23, 2023 Dear XXXXXXXXXX: Re: XXXXXXXXXX Mineral Resource Certification This is in response to your letter dated March 14, 2023, in which you requested on behalf of XXXXXXXXXX certification pursuant to subparagraph (d)(i) of the definition “mineral resource” in subsection 248(1) of the Income Tax Act (the “Act”) with respect to the lithium silicate spodumene deposits (the “Deposits”) of its XXXXXXXXXX Project (the “Project”) located in XXXXXXXXXX. ...
Technical Interpretation - External
5 April 2023 External T.I. 2023-0962281E5 - METC- Cataract surgery
5 April 2023 External T.I. 2023-0962281E5- METC- Cataract surgery Unedited CRA Tags ITA: Section 118.2, subsection 118.4(2); paragraphs 118.2(2)(a) and 118.2(3)(b). ... Underhill April 5, 2023 Dear XXXXXXXXXX: Re: Cataract Surgery We are writing in response to your correspondence dated January 31, 2023, asking whether the cost you incurred for an aspheric lens as part of cataract surgery qualifies as an eligible medical expense for the purposes of the medical expense tax credit (METC). ...
Technical Interpretation - External
23 March 2023 External T.I. 2023-0967391E5 - Incentive for nurses to go back to practice
23 March 2023 External T.I. 2023-0967391E5- Incentive for nurses to go back to practice Unedited CRA Tags 5(1); 56(1)(r)(i) Principal Issues: What is the tax treatment of amounts paid to eligible nurses under the Ontario Community Commitment Program for Nurses (CCPN) in a particular situation where employers are responsible for flowing these amounts directly to nurses? ... El-Kadi March 23, 2023 Dear XXXXXXXXXX: Re: Incentive payments to nurses under the Community Commitment Program for Nurses We are writing in response to your email of March 15, 2023, in which you ask about the tax treatment of amounts paid to eligible nurses under the Community Commitment Program for Nurses (CCPN) program. ...
Technical Interpretation - External
26 September 2023 External T.I. 2023-0984971E5 - Disposition - Shares used as loan collateral
26 September 2023 External T.I. 2023-0984971E5- Disposition- Shares used as loan collateral Unedited CRA Tags 39(1), 40(1), 248(1) "disposition" Principal Issues: Whether a disposition for tax purposes would occur at the time publicly traded shares are transferred to the Lender as collateral for a loan. ... XXXXXXXXXX Income Tax Rulings Directorate Ryan Wallace, CPA 2023-098497 Sept 26, 2023 Dear XXXXXXXXXX: Re: Disposition – Shares used as loan collateral We are writing in response to your email of July 3, 2023, wherein you requested our views on whether transferring publicly traded shares to a lender, as collateral for a loan, would result in a disposition for tax purposes. ...