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8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Paragraph 6(1)(f) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) CRA noted that an employer's group disability plan which was administered by an administrator (such as an insurance corporation) on an administrativee services only basis nonetheless would qualify as an insurance plan ("IP") (and a wage loss replacement plan ("WLRP")) for the purpose of paragraph 6(1)(f) of the Act, if it contained "an undertaking by one person to indemnify another person, for an agreed consideration, from a loss or liability in respect of an event, the happening of which is uncertain. ...

6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property-- summary under Excluded Property Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Excluded Property unpurchased goodwill is taken into account Is internally generated goodwill considered in determining whether shares of a foreign affiliate ("FA2") of a corporation resident in Canada qualify as "excluded property" of another foreign affiliate ("FA1") of the corporation? ...

22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution-- summary under Subsection 93(2.01) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(2.01) a contribution of FA1 shares to FA2 causes the FA2 shares to be substituted property for s. 93(2.01) purposes A wholly-owned foreign affiliate (“Luxco1”) of Canco held 1/3 of the shares of a corporation ("NRco") resident in a Treaty country. ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate-- summary under Subsection 90(14) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(14) deduction not dependent on FA being creditor affiliate at repayment time In 2013, FA, which is wholly-owned by Canco, makes a loan to SisterCo., which is wholly-owned by the non-resident parent of Canco (“Foreign Parent”). ...

3 March 2017 Internal T.I. 2016-0673661I7- Upstream loans – allocation of repayments-- summary under Paragraph 90(8)(a) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(8)- Paragraph 90(8)(a) ordering of upstream loan repayments determined on FIFO basis Prior to August 19, 2011, Canco borrowed $50M (“Advance A”) from its wholly-owned non-resident subsidiary (“FA”), and borrowed a further $50M (“Advance B”) from FA under the same revolving credit facility in October 2012. ...

2 May 2005 Internal T.I. 2005-0119971I7 F- CDA- Excessive Election & Late Filed Election-- summary under Subsection 83(3.1) Summary Under Tax Topics- Income Tax Act- Section 83- Subsection 83(3.1) where no s. 83(2) election filed for statute-barred year, CRA should request late election under s. 83(3.1) or, failing which, assess a taxable dividend under s. 184(4)(b)(ii) CRA never received a s. 83(2) election in respect of a dividend payable in 1997 by Yco to its sole shareholder, an individual ("Y"). ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Clause 95(2)(b)(i)(A) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(b)- Subparagraph 95(2)(b)(i)- Clause 95(2)(b)(i)(A) provision of services for fee by CFA to Canco on arm’s length terms did not oust s. 95(2)(b)(i)(A) Four U.S. ...

27 March 2018 Internal T.I. 2017-0691941I7 F- Investissement frauduleux – Fraudulent Investment-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date court order ab initio declaring loan void would eliminate interest income Individuals had “invested” in what turned out to be a Ponzi scheme under which for many years they reported annual income inclusions for interest which they were treated as having reinvested in the scheme. ...

7 June 2021 Internal T.I. 2020-0873601I7- CERS – restricted activities of a travel agency-- summary under Public Health Restriction Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Public Health Restriction a COVID lockdown closing a travel agency office qualified as a “public health restriction” even if the personnel continued bookings from home Would a travel agency that was required to close its office due to COVID lockdown measures, so that its employees started working from home, qualify for lockdown support under B of s. 125.7(2.1) and the definition of “rent top-up percentage”? ...

22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) ordinarily not applied where a shareholder owes money to a corporation under a genuine or bona fide loan arrangement Discussion of whether s. 15(1) or 56(2) might apply to loans by corporations wholly owned by an individual to a corporation that was partly owned by other persons. ...