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23 November 1993 External T.I. 9322405 F- SR & ED Unedited CRA Tags 37(1)(a)(ii) XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Scientific Research & Experimental Development (SR&ED) This is in reply to your letter of July 30, 1993 wherein you requested further clarification that a fee arrangement charged by a non-resident company to a Canadian taxpayer for the right to manufacture or produce a product developed as a result of the SR&ED performed in Canada would not jeopardize the eligibility of the SR&ED expenditures for investment tax credits (ITC). ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4 CRA Tags Treaties Article XXIV 126(7) "non-business-income tax" 20(11) Treaties Article V Principal Issues: What credits and deductions are available to U.S. citizens resident in Canada on taxes paid in respect of dividend income now that rates have increased in conjunction with the "fiscal cliff". ... Reasons: Text of the treaty. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 4. ...

10 June 2013 Roundtable, 2013-0480411C6- STEP Roundtable – June 2013- Question 10 Principal Issues: Deductibility of probate and related fees by an estate. Position: Question of fact Reasons: In our view, the Tax Court of Canada's decision under the informal procedure was based on the unique facts of the case. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 10. ...

31 December 2015 External T.I. 2014-0556881E5- Bill C-43 – Calendar year for testamentary trusts CRA Tags 248(1) Principal Issues: Change in tax treatment of testamentary trusts arising from Bill C-43 may result in a deemed tax year end of December 31, 2015. ... King December 31, 2015 Dear XXXXXXXXXX: Re: Bill C-43 – Calendar year for testamentary trusts This is in reply to your email correspondence and our telephone conversations during which you asked if there is any transitional relief with respect to the legislative changes in Bill C-43 which require an existing testamentary trust, which will not be a graduated rate estate, to have a taxation year that coincides with the calendar year; commencing with a deemed taxation year of December 31, 2015. ...

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution CRA Tags 93(2) 93(2.01) Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to shares owned by a taxpayer in respect of which the taxpayer made a capital contribution consisting of shares of another foreign affiliate? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 7 – Subsection 93(2.01) substituted property rule and capital contributions Assume the following hypothetical facts: a) Canco owns all of the shares of each of FA1 and FA2. b) Canco capitalizes FA1 with $1,000 of equity. c) FA1 loans $1,000 to FA2 for use in its active business. d) A few years later, after having paid dividends of $50 to Canco, FA1 becomes a wholly-owned subsidiary of FA2 as a result of a contribution of capital by Canco of the shares of FA1 to FA2. ...

13 February 2017 Roundtable, 2017-0684491C6- CPA-BC & CRA Roundtable 2017 Principal Issues: Whether the CRA will re-introduce a dedicated phone line for tax professionals. ... CPA-BC & CRA Roundtable 2017 Question 16: We were very excited about the introduction of the CRA’s “professional designated phone line”, only to find out that this was meant for small practitioners who have no tax advisers. ...

10 July 1980 Income Tax Severed Letter 5-1027 F- [] Unedited CRA Tags 95(2)(a)(ii), Reg. 5907(11), 5907(11)a)(i) Dear Sirs: RE:     Taxable Surplus and Subparagraph 95(2)(a)(ii)of the Income Tax Act (the Act) This is in reply to your letter of December 11, 1970 requesting our views on the application of subparagraph 95(2)(a)(ii) of the Act. ...

8 June 2018 Internal T.I. 2018-0744881I7- Regulation 403 – allocation of income Unedited CRA Tags 138, 248 (definition of insurance corporation), Regulations 400 and 403 Principal Issues: For the purposes of taxable income allocation under Regulation 403, should the taxpayer ignore the PEs of the partnerships in which the taxpayer is a partner? ... & Investigations Branch Lata Agarwal, CPA, CMA, MBA 2018-074488 Provincial income allocation – permanent establishments of insurance corporation We are writing in response to your email dated February 20, 2018, in which you have asked us to confirm the CRA’s position stated in technical interpretation (“TI”) E56239 that each member of a partnership has a permanent establishment (“PE”) in the province in which the partnership has a PE. Your email describes a corporate taxpayer that filed Form T2 Schedule 5, Tax Calculation Supplementary – Corporations, for its XXXXXXXXXX taxation year, as an insurance corporation under section 403 of Part IV of the Income Tax Regulations (the “Regulations”). ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit Unedited CRA Tags 126 4 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Other jurisprudence that supports the principle that a business is generally considered to be carried on in the place where the operations from which the profits arise are located and not necessarily where the sales contracts are made include: (a) F.L.Smidth & Co. v. ... (b) Firestone Tyre & Rubber Co., Ltd. V. Lewellin (HM Inspector of Taxes) (1957, 37 TC 111, at 142, "It follows then that the place of sale will not be the determining factor if there are other circumstances present that outweigh its importance or unless there are no other circumstances that can. ...

20 June 2007 Internal T.I. 2006-0178941I7- Foreign Spin-off & Foreign Merger Unedited CRA Tags 86.1(1) 87(8) 87(8.1) Principal Issues: 1. ... Newco shares were not listed under a symbol proper. • No information concerning the buying or selling transactions of Newco shares were provided. ... Olli Laurikainen, CA for Director International & Trusts Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch ...