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7 January 2009 Internal T.I. 2008-0304901I7- Taxation & Insolvency Unedited CRA Tags 164(1) Principal Issues: Whether all post-bankruptcy refunds vest automatically in a trustee in bankruptcy. ... Diegel & Feick Inc. (1980), 35 C.B.R. (N.S.) 309 (Ont. S.C.); Re Sihler (1982), 43 C.B.R. ...

5 November 1998 External T.I. 9818445- JOINT TENANTS & TENANTS IN COMMON Unedited CRA Tags 70(5) 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. ... Reasons: The provision of subsection 70(5) will deemed the interest in the property to be disposed of at fair market value under both tenancy arrangements. 5-981844 XXXXXXXXXX Karen Power, CA (613) 957-8953 November 5, 1998 Dear XXXXXXXXXX: Re: Joint Tenancy & Tenants in Common We are writing in reply to your letter of June 8, 1998, concerning the taxation of property owned by yourself and your brother and sister. ...

7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6- TOSI & Meaning of Excluded Business Unedited CRA Tags 120.4 Principal Issues: Whether dividend income earned by a spouse who works as a part-time receptionist in the business would be subject to TOSI. ... Reasons: See below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 4. ...

1 August 2019 External T.I. 2018-0768561E5- Application Administrative Position on US LLPs & LLLP Unedited CRA Tags 248(1) "corporation" Principal Issues: Further to the CRA's administrative position that a LLP or LLLP formed before April 26, 2017 that would otherwise be viewed as a corporation by the CRA may in certain circumstances continue to be viewed as a partnership, what are the Canadian tax implications of the LLLP described in this letter subsequently taking the position that it is a corporation for Canadian tax purposes? ... Moreno August 1, 2019 Dear XXXXXXXXXX: Re: Administrative Position on US LLPs & LLLPs This is in reply to your letter of June 29, 2018. ...

8 July 2020 CALU Roundtable Q. 3, 2020-0842151C6- Insurance Proceeds & CDA Unedited CRA Tags "capital dividend account" defn in ss. 89(1); s. 148; ss. 248(1), Reg. 306, Reg.1401(3) Principal Issues: Whether the "fund value" portion of a payment made under an exempt single-life life insurance policy by an insurer to a corporation as a consequence of the death of the life insured under the policy is "proceeds of life insurance" for purposes of subparagraph (d)(ii) of the definition of capital dividend account in subsection 89(1). ... The scheme of these rules generally provide for the taxation of amounts received by a policyholder out of the policy prior to the death of the life insured under the policy, but on a tax-free basis where they are paid out as a consequence of the death of the life insured. 2020 CALU CRA Roundtable – July 2020 Question 3- Proceeds of an Insurance Policy and Calculation of the CDA credit Background One of the death benefit patterns permitted under a Universal Life (UL) policy is often referred to as “face amount plus fund value”. ...

5 May 2021 IFA Roundtable Q. 3, 2021-0888281C6- IFA 2021 Q.3: 247(3)- C$5 M Threshold & 261(5) Unedited CRA Tags 247(3), 261(5)(b), 261(5)(c). ... Reasons: Interpretation of the Act. 2021 International Fiscal Association Conference CRA Roundtable Question 3 – Application of subsection 261(5) to the $5M threshold of subsection 247(3) Assume that a Canadian corporation (“Canco”) with an “elected functional currency”, within the meaning of subsection 261(1), is subject to “transfer pricing income adjustments”, as defined in subsection 247(1), in respect of a “functional currency year”, as per the meaning of that expression under subsection 261(1). ...

17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Unedited CRA Tags Article XXX(3) of the Canada-Barbados Treaty Principal Issues: Under the Insurance Act (Barbados), a Class 2 licence entitles the company to insure third-party risks wherever situated. ... Reasons: See below. 2023 IFA Annual Conference CRA Roundtable Question 4- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Paragraph 3 of Article XXX (Miscellaneous Rules) of the Canada-Barbados Income Tax Convention (“the Treaty”) provides: 3. ...

15 September 2020 IFA Roundtable Q. 6, 2020-0853561C6- Subsection 212.3(9) & The GAAR Unedited CRA Tags 18(4), 212(2), 212.3(9), 245(2). ... Reasons: See below. 2020 International Fiscal Association Conference CRA Roundtable Question 6 – Subsection 212.3(9) and The GAAR At all relevant times, a non-resident corporation owns all the common shares of a corporation resident in Canada (Canco), which shares are the only issued and outstanding shares of Canco. ...

21 February 2024 External T.I. 2022-0951441E5- Replacement Property – Undivided Interest Unedited CRA Tags 13(4), 13(4.1), 44(1), 44(5), 54 "capital property", 248(1) “Property" Principal Issues: Where a taxpayer acquires an undivided interest in a particular property, whether the particular property can qualify as a "replacement property”, as defined by subsections 13(4.1) and 44(5) of the Act? ... XXXXXXXXXX 2022-095144 Troy Neave February 21, 2024 Dear XXXXXXXXXX: Re: Replacement Property – Undivided Interest We are writing in response to your letter dated September 3, 2022, wherein you requested our views on whether, for purposes of the replacement property rules in subsections 13(4) and 44(1) of the Income Tax Act (the “Act”), a particular property could be considered a replacement property if the nature of ownership is an undivided interest. ...

25 March 2025 External T.I. 2025-1049301E5- METC- Hyperbaric oxygen chamber & concentrator Unedited CRA Tags Subsection 118.2(2) ITA; Paragraphs 118.2(2)(i) and (k) ITA; Paragraph 118.4(2)(c) ITA Principal Issues: Whether the amounts paid to acquire 1) a portable oxygen concentrator and 2) a hyperbaric oxygen chamber would qualify as eligible medical expenses for the purposes of the medical expense tax credit (METC). ... XXXXXXXXXX 2025-104930 Éloïse Lafortune Viger March 25, 2025 Dear XXXXXXXXXX, Re: Medical Expense Tax Credit – Portable Oxygen Concentrator and Hyperbaric Oxygen Chamber We are writing in response to your letter dated October 16, 2024, inquiring whether the amounts paid to acquire a portable oxygen concentrator and a hard shell hyperbaric oxygen chamber would qualify as eligible medical expenses under subsection 118.2(2) of the Income Tax Act (the “Act”) for the purposes of the medical expense tax credit (“METC”). ...