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3 April 2023 Internal T.I. 2023-0967941I7- Adjusted Aggregate Investment Income Unedited CRA Tags 125(7); 125(5.1)(b), 129(4) Principal Issues: See Interpretation April 3, 2023 Mr. Yves Thivierge Income Tax Rulings Directorate Corporate Income Tax Legislative Christina Foggia, CPA, CA Amendments Section Legislative Policy Directorate Canada Revenue Agency 2023-096794 Adjusted Aggregate Investment Income This is in reply to your correspondence of March 16, 2023, wherein you requested our views on whether the Adjusted Aggregate Investment Income (“AAII”) of a corporation for a taxation year, as defined in subsection 125(7) of the Income Tax Act (“Act”), which is relevant for purposes of calculating a corporation's business limit reduction under paragraph 125(5.1)(b) of the Act (“BL Reduction”), can be a negative amount. ...

29 December 2023 Internal T.I. 2023-0998801I7- Payments to Low-Income Seniors Benefit recipients Unedited CRA Tags 56(1)(u); ITR 233(2); Section 52 of New Brunswick's Income Tax Act. ... December 29, 2023 Legislative Policy Directorate HEADQUARTERS Provincial Legislative Affairs Section Income Tax Rulings Directorate Randa El-Kadi Attention: Cornelis Rystenbil 2023-099880 Re: Government of New Brunswick Low Income Seniors’ Affordability Supplement This is in reply to your email of November 21, 2023 requesting our guidance on the tax treatment of an affordability payment that the Government of New Brunswick (GNB) intends to provide to recipients of the Low-Income Seniors’ Benefit (LISB). ... In the interim, the GNB will issue a non-legislated $200 Low Income Seniors’ Affordability Supplement (LISAS) for each of the 2023 and 2024 benefit years. ...

16 October 2023 Internal T.I. 2018-0779061I7- Deducting losses for AMT purposes Unedited CRA Tags 127.52(1)(i)(i), 111(1)(a), 164(3) Principal Issues: Whether non-capital losses considered under clause 127.52(1)(i)(i)(B) can be from different taxation years than those actually deducted for the taxation year under paragraph 111(1)(a). ... XXXXXXXXXX 2018-077906 Julia Clarkson October 16, 2023 Dear XXXXXXXXXX: Re: Non-capital losses for AMT purposes This is in reply to your letter requesting our views on whether a taxpayer can deduct a non-capital loss for alternative minimum tax (AMT) (or Division E.1) purposes when that taxation year’s non-capital loss has not yet been claimed for income tax (Division E) purposes under paragraph 111(1)(a) of the Income Tax Act. ... Note that legislation released on August 4, 2023 proposes to restrict the amount of losses deducted under paragraph 111(1)(a) and (e) to 50% of the amounts deducted for Division E purposes. ...

8 September 2023 Internal T.I. 2023-0987091I7- Trailing Commissions and Dealer Rebates Unedited CRA Tags 12(1)(x); 12(2.1) Principal Issues: Whether the CRA would be able to provide an interpretation that a certain rebate to be paid by a dealer to unitholders in a mutual fund trust would not be included in the income of the mutual fund trust pursuant to paragraph 12(1)(x) and subsection 12(2.1) of the Act. ... September 8, 2023 XXXXXXXXXX Income Tax Ruling Directorate Trust Section I Judith Harris 2023-098709 Attention: XXXXXXXXXX RE: Application of Subsection 12(2.1) of the Income Tax Act to Trailer Fee Rebates We are writing in response to your recent question regarding the application of subsection 12(2.1) of the Income Tax Act to rebates that may be paid by certain securities dealers to unitholders of mutual fund trusts. ... We understand that during the period from June 1, 2022 to a later date specified by securities regulators, (initially November 30, 2023 but now extended in the case of Ontario to May 31, 2025), certain OEO Dealers and mutual funds are exempted from this OEO trailer ban where a trailing commission is paid by the mutual fund or its organization to the OEO Dealer to facilitate the OEO Dealer paying a rebate of such amount to its clients who held their investment in the mutual fund prior to June 1, 2022, and to clients who transferred mutual fund units held by them into OEO Dealer accounts on or after June 1, 2022 (“OEO Rebate”). ...

18 January 2023 Internal T.I. 2022-0940131I7- U.S. Dependency and Indemnity Compensation Unedited CRA Tags 56(1)(d); Canada-U.S. ... XXXXXXXXXX 2022-094013 January 18, 2023 Dear XXXXXXXXXX: Re: U.S. Dependency and Indemnity Compensation We are writing in reply to your email of May 30, 2022 in connection with the treatment under the Income Tax Act (the “Act”) of payments of Dependency and Indemnity Compensation (DIC) benefits received by a Canadian resident taxpayer from the United States Department of Veterans Affairs. ...

26 May 2023 Internal T.I. 2023-0962611I7- Paragraph 60(v.2) deduction for a bankrupt Unedited CRA Tags 60(v.2), 8(2) of the CRB Act Principal Issues: 1. ... May 26, 2023 Legislation Section HEADQUARTERS Common Tools and Support Division Income Tax Rulings Directorate IPRRD, ABSB Julia Clarkson Attention: André Perrier 2023-096261 Paragraph 60(v.2) deduction for a bankrupt individual taxpayer All statutory references in this document are to the Income Tax Act, R.S.C. 1985, (5th Suppl.) c.1, as amended (the Act), unless stated otherwise. We are writing in reply to your email of February 3, 2023, and related correspondence in which you request our guidance on how to interpret the application of paragraph 60(v.2) to a bankrupt individual taxpayer that has two taxation years within a calendar year. ...

9 March 2023 Internal T.I. 2022-0950431I7- BC MCFD- Youth transition payments Unedited CRA Tags Section 3, 5 and 9; Paragraphs 56(1)(u) and 81(1)(h) Principal Issues: Whether the proposed payments from the Government of British Columbia MCFD to former foster care providers in the province would meet the income exclusion requirements of paragraph 81(1)(h). ... March 9, 2023 Cornelis (Kees) Rystenbil Income Tax Rulings Directorate Manager, LPRAB Business and Employment Division Cynthia Underhill 2022-095043 Proposed housing agreement payments– tax implications and reporting requirements We are writing in response to the submission from the Government of British Columbia (BC) Ministry of Children and Family Development (MCFD) requesting the Canada Revenue Agency’s (CRA) views on the tax consequences of the proposed Housing Agreement (HA) payments received by a former foster care parent (caregiver). ... The BC government expects to introduce the legislation in the spring of 2023. ...

11 April 2023 Internal T.I. 2023-0964101I7- Tax issues for cross-border employees Unedited CRA Tags s.126, Paragraph 2(b)(iii) of Article II, Article XVIII:10, 11, and Article XXIV:2 of the Canada-US Treaty. ... Jess Johns International Tax Division 2023-096410 International and Large Business Directorate Grace Tu Compliance Programs Branch April 11, 2023 Dear Jess Johns: Re: Hybrid work arrangement for Canadian-resident cross-border employees We are writing in response to your request regarding certain income tax implications concerning Canadian residents who work for a United States (“U.S.”) based employer and who either commute to the U.S. or stay in Canada to perform their employment duties (the “cross-border employees”). ...

31 January 2023 Internal T.I. 2022-0956851I7- Ontario Energy and Property Tax Credit Unedited CRA Tags Ontario Taxation Act, 2007 98(2), 98(5), 103.9(3) Principal Issues: Are tenants who live in rent geared to income housing eligible to claim the OEPTC where the housing provider receives a property tax subsidy after paying their assessed property taxes in full? ... Wirag, CPA, CMA January 31, 2023 Dear XXXXXXXXXX, Re: Ontario energy and property tax credit We are writing in response to your email of November 21, 2022, regarding your questions about the Ontario energy and property tax credit (OEPTC). ...

28 February 2023 Internal T.I. 2019-0791421I7- Appl of 165(1) where no change to tax payable Unedited CRA Tags 152(2), 152(4), 165(1), 169(1) Principal Issues: Where a taxpayer request to amend a return of income is denied, which results in no change to any element of the return and no change is made to tax payable previously assessed, is the notice of a denial of the request a reassessment to which the objection rights provide by subsection 165(1) of the Income Tax Act are applicable. ... February 28, 2023 Guy Mercure HEADQUARTERS Program Management Division Income Tax Rulings Directorate SR&ED Directorate G. ...