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30 September 2013 Internal T.I. 2012-0439661I7- Income earmarked for future use & 95(2)(a)(i) CRA Tags 95(1) 95(2)(a)(i) Principal Issues: Whether the income earned by one foreign affiliate on property that is earmarked for future development of another foreign affiliate's active business can be included in income from active business under paragraph 95(2)(a). ... In other words, the property has to be an integral part of the financing of the business or necessary to the overall business operations in order for income from the property to be part of the income of the corporation … from an active business. ... MNR, 87 DTC 450 at 457; McCutcheon Farms, supra note 2 at 1214; Transport Lacte Inc, supra note 3 at 610; Muir Cap & Regalia Ltd v. ...

6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property CRA Tags 110.6(1) 95(1) 149(10) Principal Issues: Whether internally generated goodwill should be considered in the determination of the excluded property status of shares of a foreign affiliate held by another foreign affiliate? ... Truong: Internally Generated Goodwill & Excluded Property Status We are writing in response to your e-mail dated June 25, 2014 wherein you asked whether internally generated goodwill should be considered in determining whether shares of a foreign affiliate ("FA2") of a corporation resident in Canada qualify as "excluded property", as that term is defined in subsection 95(1) of the Income Tax Act (the "Act"), of another foreign affiliate ("FA1") of the corporation. ... Our comments The relevant part of the definition "excluded property" in subsection 95(1) reads as follows: "excluded property", at a particular time, of a foreign affiliate of a taxpayer means any property of the foreign affiliate that is (a) used or held by the foreign affiliate principally for the purpose of gaining or producing income from an active business carried on by it, (b) shares of the capital stock of another foreign affiliate of the taxpayer where all or substantially all of the fair market value of the property of the other foreign affiliate is attributable to property, of that other foreign affiliate, that is excluded property, […] Pursuant to paragraph (b) of that definition, the shares of FA2 will qualify as excluded property of FA1 if all or substantially all of the fair market value of FA2's property is attributable to property that is excluded property. ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C) CRA Tags 94(3) Principal Issues: Can a non-resident trust that is subject to "new" subsection 94(3) deduct an amount under subsection 91(5) in respect of a FAPI inclusion resulting from the application of "old" clause 94(1)(c)(i)(C)? ... Mark Turnbull, Team Leader HEADQUARTERS International Advisory Services Section Income Tax Rulings International and Large Business Directorate Directorate Yannick Roulier 2015-059849 91(5) Deduction – Non-Resident Trust Subject to “Old” Clause 94(1)(c)(i)(C) This letter is in reply to correspondence received from XXXXXXXXXX, an International Tax Auditor with the XXXXXXXXXX Tax Services Office, on July 14, 2015, wherein she requested our assistance in respect of the possible application of subsection 91(5) to a particular situation involving a non-resident trust. ... Comments The relevant portions of “old” subparagraph 94(1)(c)(i) read as follows: (i) the trust is deemed for the purposes of this Part and sections 233.3 and 233.4 to be a person resident in Canada no part of whose taxable income is exempt because of section 149 from tax under this Part and whose taxable income for the year is the amount, if any, by which the total of (…) (C) the amount, if any, by which the total of all amounts each of which is an amount required by subsection 91(1) or (3) to be included in computing its income for the year exceeds the total of all amounts each of which is an amount deducted by it for that year under subsection 91(2), (4) or (5), and Based on the wording of “old” clause 94(1)(c)(i)(C), the FAPI-Inclusions consist of net amounts of inclusion resulting from the application of subsections 91(1) or (3), and subsections 91(2), (4) or (5), as the case may be, in computing NRT’s income for its 2002, 2004 and 2006 taxation years. ...

12 January 2022 Internal T.I. 2021-0920371I7- METC – Cost of a cast Unedited CRA Tags Section: 118.2; paragraphs 118.2(2)(i) and (m), paragraph (i) of Regulation 5700 Principal Issues: Whether the cost of a walking cast would qualify as an eligible medical expense for the purposes of the METC. ... January 12, 2022 Marie-Pier Valiquette Income Tax Rulings Directorate A/Senior Programs Officer, Business and Employment Division Sales Tax and Benefits Information Cynthia Underhill Section, ABSB 2021-092037 Medical expense tax credit – eligibility of a walking cast We are writing in response to your email dated December 8, 2021, asking if the cost of a walking cast would qualify as a medical expense for purposes of the medical expense tax credit (“METC”), under section 118.2 of the Income Tax Act (Act). ... Section 5700 of the Regulations states: “[Prescribed device or equipment] — For the purposes of paragraph 118.2(2)(m) of the Act, a device or equipment is prescribed if it is a... ...

26 July 2012 External T.I. 2011-0431681E5- Taxable Benefits – Recreational Facilities Unedited CRA Tags 6(1)(a) Principal Issues: 1. ... Baltkois July 26, 2012 Dear XXXXXXXXXX: Re: Taxable Benefits – Recreational Facilities We are writing in response to your fax dated December 8, 2011, in which you requested our comments as to whether an employee’s use of an employer provided in-house fitness centre would result in a taxable benefit. ...

18 March 2014 External T.I. 2013-0511191E5- Taxable Benefits – Weight Management Programs CRA Tags 6(1)(a) 6(1)(a)(iv) Principal Issues: Whether an employer-subsidized weight management program is a taxable employment benefit? ... Baltkois March 18, 2014 Dear XXXXXXXXXX: Re: Taxable benefits – weight management program We are writing in response to your correspondence dated November 1, 2013, wherein you requested our comments concerning whether a weight management program subsidized by an employer as part of an overall wellness initiative would result in a taxable benefit to participating employees. ...

25 September 2012 CTF Roundtable Q. 4, 2012-0457581C6- CTF BC – Q4 Residency of a Trust Principal Issues: Impact on the CRA published position in relation to the factors it considers indicative for purposes of establishing residency of a trust in light of the 2012 SCC decision in St. ... Reasons: Comments as previously published by the Directorate British Columbia Tax Conference September 25, 2012 Question 4 – Residency of a Trust for Tax Purposes CRA's long-standing position on the determination of the residency of a trust for tax purposes is described in IT-447 Residence of a Trust or Estate (published in 1980). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c) CRA Tags 93.2 Principal Issues: Whether paragraph 95(2)(c) applies in a situation where a taxpayer transfers shares of a foreign affiliate to another foreign affiliate that is a “non-resident corporation without share capital”, within the meaning of subsection 93.2(1), without any “shares” being issued as consideration? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 10 – Interaction of section 93.2 and paragraph 95(2)(c) It is our understanding that subsection 93.2(3) was introduced with the specific purpose of facilitating the application of paragraph 95(2)(c), among other provisions, to “non-resident corporations without share capital”, within the meaning of subsection 93.2(1). ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election CRA Tags 108(1) Principal Issues: 1. ... STEP CRA Roundtable – June 10, 2016 Question 4. Qualified Disability Trust and Preferred Beneficiary Election There are a number of conditions that must be met in order for a trust to be eligible to be a Qualified Disability Trust (“QDT”) for a particular tax year. ...

26 May 2016 External T.I. 2016-0627441E5- Employment expenses – long-haul truck driver Unedited CRA Tags 8(2), 8(1)(g), 8(1)(h), 8(1)(h.1), 8(1)(i)(iii), 8(1)(j), 8(4), 8(10), 67.1(1), 67.1(5), 67.1(1.1), 230(1), 248(1) Principal Issues: Deductibility of expenses by a long-haul truck driver. ... Underhill May 26, 2016 Dear XXXXXXXXXX: Re: Employment expenses – long-haul truck driver We are writing in response to your letter dated December 29, 2015, concerning what expenses a long-haul truck driver may deduct from his or her employment income. ...