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These are additions to our set of 1,849 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 1,859 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 1,890 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 1,898 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 1,907 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ½ years of releases of such items by the Directorate. ...

Repairs or Running Expense Belgega-finding that inducement paid to prospective emphyteuta (tenant) was capital expenditure- noted 9 June 2005 Internal T.I. 2005-0122511I7 F- Créance irrécouvrable dans une OSBL Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c)- Subparagraph 39(1)(c)(iv) loss on interest-bearing loan made by a director to an NPO qualified as BIL if NPO qualified as SBC Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(g)- Subparagraph 40(2)(g)(ii) a debt obligation bearing a reasonable rate of interest satisfies s. 40(2)(g)(ii) 9 June 2005 External T.I. 2004-0097451E5 F- Régimes d'assurances collectives Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) employees can potentially pay top-up amounts for further benefits or receive taxable compensation for opting for lower benefits Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) CRA criteria for determining whether there are 2 separate plans (one of which is fully employee-funded) 6 June 2005 External T.I. 2005-0114481E5 F- Division 149(1)o.2)(ii)(C) Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(B) deferred proceeds receivable for real estate sale do not qualify as real property Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(C) loan that funded rental property acquisition may still qualify after partial sale of portfolio/replacement borrowing can also qualify Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) loan that funded rental property acquisition may still qualify as “solely for the purpose of earning income” per s. 149(1)(o.2)(ii)(C) after partial sale of portfolio 9 June 2005 Internal T.I. 2005-0115481I7 F- Avantages imposables/voyages Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) since the particular shareholder-employees who benefited from trips provided by their employer’s supplier were known, the supplier should issue T4As to them Income Tax Regulations- Regulation 200- Subsection 200(2)- Paragraph 200(2)(g) T4As required to be issued to shareholder-employees of customers who were identifiable as receiving free trips – but not for sole proprietor customers 9 June 2005 Internal T.I. 2005-0117851I7 F- Choix du paragraphe 14(1.01) de la Loi Income Tax Act- Section 14- Subsection 14(1.01) taxpayer could not make s. 14(1.01) election where "exempt gains balance" in respect of his business for the year is not nil 7 June 2005 External T.I. 2005-0121551E5 F- Déduction des intérêts- co-emprunteurs Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed from spouse under line of credit for income-producing purpose is deductible ...

In Example 3, per “ Geransky and Kennedy, the sale of the capital assets in and of itself should not constitute a reorganization for the purposes of subsection 84(2) provided that R Co continues to carry on the same business.” ...

These are additions to our set of 1,977 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 16 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2005-04-01 23 March 2005 Internal T.I. 2005-0113931I7 F- Safe income on hand calculation: Life Insurance Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) non-deductible life insurance premiums reduced SIOH 2005-03-25 22 March 2005 External T.I. 2005-0112081E5 F- Convention de retraite- lettre de crédit Income Tax Act- Section 207.7- Subsection 207.7(2) where LC used to secure RCA benefits and refundable tax generated on funding of LC fees, refundable tax not recoverable based on paying the benefits Income Tax Act- Section 207.5- Subsection 207.5(1)- Refundable Tax use of letter of credit to secure RCA benefits Income Tax Act- Section 207.5- Subsection 207.5(2) election not available to custodian holding an LC 22 March 2005 Internal T.I. 2005-0115451I7 F- Extinction d'une remise de dette Income Tax Act- Section 80- Subsection 80(1)- Forgiven Amount no deduction where forgiven debt is subsequently restored pursuant to improved fortunes clause Income Tax Act- Section 80.01- Subsection 80.01(10) repayment deduction under s. 80.01(10) General Concepts- Effective Date CRA assesses based on the state of affairs at year end 2005-03-18 1 February 2005 External T.I. 2004-0083921E5 F- Société mandataire, gain & CIÉ Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax US taxes paid by a corporation based on falsely representing that the related gain was its gain could generate a FTC to the Canadian shareholder for which it in fact was agent 4 February 2005 External T.I. 2004-0085361E5 F- Changement de résidence: émigration Income Tax Act- Section 122.6- Eligible Individual- Paragraph (c) required repayment of CCB if received after departure from Canada 31 January 2005 External T.I. 2004-0091301E5 F- Déductions à la source-avantage autre qu'en argent Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no source deductions required where a non-cash benefit is the sole remuneration Income Tax Act- Section 153- Subsection 153(1.1) no source deductions required where free accommodation was the intern's only benefit 4 February 2005 External T.I. 2004-0093611E5 F- Don par testament d'un bien culturel Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(a)- Subparagraph 39(1)(a)(i.1)- Clause 39(1)(a)(i.1)(B) s. 39(1)(a)(i.1) unavailable where capital gain realized under s. 104(4)follow-up in 2005-0131741E5 F 15 March 2005 Internal T.I. 2004-0108721I7 F- Don d'une licence Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts gift of a non-exclusive software licence was a gift of property Income Tax Act- Section 248- Subsection 248(1)- Property excepting WIP, definition of property is no broader than term’s ordinary meaning ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2022-04-06 2017 Ruling 2017-0696791R3 F- Reduction of PUC/capital Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by Subco for distribution of share-capital account to its parent is deductible if the Subco property continues generating business incomeAmended and supplemented by 2017-0696792R3 F Income Tax Act- Section 51- Subsection 51(1) s. 51(1) will apply where convertible note, that was issued as boot, will be converted to sharesAmended and supplemented by 2017-0696792R3 F 2019 Ruling 2017-0696792R3 F- Internal reorganization Amending and supplementing 2017-0696791R3 F 7 January 2022 External T.I. 2020-0866751E5 F- CEWS and government financial assistance Income Tax Act- Section 125.7- Subsection 125.7(4) government assistance based partly on payroll levels would not be qualifying revenue if normal accounting practice would be to contra payroll expense Income Tax Act- Section 125.7- Subsection 125.7(1)- Qualifying Revenue government assistance that under normal accounting practice was applied to reduce recorded expenses would not be qualifiying revenue 2005-03-11 3 March 2005 External T.I. 2004-0096371E5 F- Revenu tiré d'un emploi et 110(1)f)(iii) Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(f)- Subparagraph 110(1)(f)(iii) no special tests under s. 110(1)(f)(iii) for determining whether the individual is self-employed 2005-03-04 7 February 2005 External T.I. 2004-0101421E5 F- Subsection 111(5.1) General Concepts- Fair Market Value- Other depreciable assets’ value inferred from the share purchase price Income Tax Act- Section 111- Subsection 111(5.1) FMV of assets should be established on a push-down basis from the share purchase price, but can be allocated based on an appraisal 28 February 2005 Internal T.I. 2004-0103991I7 F- Remboursement de frais de scolarité Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(n) agreement of employer to pay tuition would have been taxable under s. 6(3) if a benefit Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment of tuition fees conditional on a return to extended employment was not a taxable benefit 28 February 2005 External T.I. 2004-0104121E5 F- Détermination du statut de résidence Income Tax Regulations- Regulation 2607 individual working in Ontario but visiting Quebec family home twice monthly likely was resident in Quebec 7 February 2005 External T.I. 2005-0111431E5 F- Death of a Taxpayer- Deduction of CCDE Income Tax Act- Section 66.2- Subsection 66.2(2) CCDE balance cannot be deducted in terminal return or by estate Income Tax Act- Section 70- Subsection 70(5.2) no s. 70(5.2) deduction where CCDE balance arose “through” a partnership 23 February 2005 External T.I. 2004-0093921E5 F- Déménagement d'un employé-Paiement de frais Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) payment of house-hunting fee for new hire was non-taxable 2005-02-25 17 February 2005 External T.I. 2004-0091811E5 F- Exemption pour résidence principale Income Tax Act- Section 54- Principal Residence separate municipal addresses not determinative that basement occupied by son and ground floor occupied by mother were two housing units Income Tax Act- Section 54- Principal Residence- Paragraph (a) where residence held by son and mother in equal co-ownership is 2 units each occupied separately, each could technically access the exemption for only a ¼ interest 17 February 2005 External T.I. 2004-0104331E5 F- Indemnisation et autres paiements Income Tax Act- Section 5- Subsection 5(1) portions of settlement payment that compensated for lost vacation credits and reimbursed for psychotherapy and medication costs were taxable under s. 5(1) ...