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15 January 2004 Internal T.I. 2003-0026827- Non-resident & Tuition & Educations credits-- summary under Section 118.9 Summary Under Tax Topics- Income Tax Act- Section 118.9 no ability of child to transfer the credit where she was a non-resident with no Cdn. source of income A Canadian-resident father is claiming tuition and education tax credits transferred under s. 118.9 from his non-resident daughter who has been living with her mother in the U.S. since the couple’s divorce and has now been attending university in the U.S. ... The Directorate stated: Based on the line of reasoning in Oceanspan … and other cases … an individual who is not resident in Canada and who has no Canadian source income would not be entitled to the tuition and education tax credits. The individual is not liable to pay tax in Canada, and therefore has no need to utilize the provisions permitting the tax credits. … If the daughter was required to compute tax payable under Part I of the Act, then we agree that she would be entitled to the tuition tax credit under section 118.5 of the Act, assuming she otherwise qualified. … These credits, then, would be eligible for transfer to her father under the rules in sections 118.81 and 118.9. ...

7 May 1995 Internal T.I. 9510220- PART I.3, O/S CHEQUES & OVERDRAFTS-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt conditional payment principle accepted Bank overdrafts are considered to have arisen to the extent that they have been utilized or drawn upon. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Subsection 5903.1(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 5903.1- Subsection 5903.1(1) FACL carryback from transitional year In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ... " See summaries under Reg. 5901(2)(b) and Reg. 5907(1) – net earnings. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Subsection 220(3.2) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.2) no relief for late-filed Reg. 5901(2)(b) election A Reg. 5901(2)(b) election, to have a dividend treated as paid out of pre-acquisition surplus, must be made by the filing-due date for the taxation year in question, even where CRA subsequently assesses the year in question so as to change the relevant surplus balances. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Regulation 600 Summary Under Tax Topics- Income Tax Regulations- Regulation 600 no relief for late-filed Reg. 5901(2)(b) election A Reg. 5901(2)(b) election, to have a dividend treated as paid out of pre-acquisition surplus, must be made by the filing-due date for the taxation year in question, even where CRA subsequently assesses the year in question so as to change the relevant surplus balances. ...

10 June 2019 Internal T.I. 2019-0796221I7 F- Qualification d’un véhicule à titre de « voiture de tourisme »-- summary under Paragraph 13(7)(b) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(b) s. 13(7)(b) applies when passenger vehicle converted to taxi use A "passenger vehicle” initially acquired for personal use and subsequently converted to taxi use will at that time be considered by virtue of s. 13(7)(b) to have been “acquired primarily for use as a taxi,” so that such quoted exclusion from the s. 248(1) definition of “passenger vehicle” would thereafter apply. ...

10 June 2019 Internal T.I. 2019-0796221I7 F- Qualification d’un véhicule à titre de « voiture de tourisme »-- summary under Automobile Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Automobile a passenger vehicle ceases to qualify as such when it commences to be used as a taxi given the s. 13(7)(b) deemed acquisition When asked as to the qualification of a vehicle as a "passenger vehicle” where it initially was acquired for personal use and subsequently began to be used primarily as a taxi, CRA noted that this definition turned on that of "automobile," which excluded a motor vehicle acquired primarily for use as a taxi and that, by virtue of a deemed acquisition under the change of use rules in s. 13(7), the “acquired primarily for use as a taxi” condition is satisfied on the change of use. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Paragraph 5901(2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b) no relief for late-filed Reg. 5901(2)(b) election In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Net Earnings Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1)- Net Earnings surplus pools are not to be retroactively adjusted for a FACL carryback In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ...

A) likely could not deduct his reimbursement payment, CRA stated: … Mr. ... This court decision then eliminated any possibility of dividend income …. In short … it becomes difficult … to demonstrate the existence of a sufficient link between the expense and Mr. ...