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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. ...

7 February 1994 External T.I. 9309865 F- 6363-1 Foreign Affiliates / Cross-shareholdings / Surplus-- summary under Subsection 5902(2) Summary Under Tax Topics- Income Tax Regulations- Regulation 5902- Subsection 5902(2) Where a corporation resident in Canada owns 95% of the common shares of FA1 which, in turn, owns 100% of the common shares of FA2 which, in turn, owns 5% of the commons shares of FA1, and the Canadian corporation disposes of its shares of FA1 to a third party and elects under s. 93(1), FA2 will be the particular foreign affiliate for the purposes of Regulation 5902(2)(a). ...

15 November 2006 External T.I. 2006-0190041E5 F- Biogas / Codigestion Process / Produced for Sale-- summary under Class 43.1 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 43.1 supplementation of manure with organic waste in input to anaerobic digester would disqualify it as Class 43.1 property, as would the sale of more than 50% of the biogas produced Opco, which utilizes biomass through anaerobic digestion processes in order to produce biogas (containing significant methane) will install a "digester" which, in order to increase its performance, will use a "co-digestion" process, i.e. a process that provides for the addition of, for example, organic waste to the manure, to increase biogas equivalent. ... Regarding the methane sales it stated: [T]he sale of methane is not in itself an eligible use of biogas for the purpose of determining whether property that is part of a biogas production system can be included in Class 43.1 …. ...

23 June 2014 External T.I. 2014-0528271E5 F- Terrain « adjacent » à la résidence principale-- summary under Principal Residence Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence meaning of immediately contiguous lands The taxpayers, whose "Lot 1" included a floodplain, were legally precluded from expanding their residence until they purchased the nearby "Lot 2. ...

15 December 2006 External T.I. 2006-0182471E5 F- Intérêts " explicitement identifiés "-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) whether a court order or settlement “explicitly identifies” pre-judgment interest, so as to be taxable, is question of fact Regarding requested clarification of the position in Income Tax Technical News No. 30 that all pre-judgment interest, which is “explicitly identified” as interest in a court order or out-of-court settlement, will be taxed as interest income, CRA stated: [T]he tax treatment of pre-judgment interest explicitly identified as described in your request varies according to the specific terms and conditions of each judgment or out-of-court settlement. ...

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. ...

15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency-- summary under Paragraph 261(5)(a) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(5)- Paragraph 261(5)(a) different currency reporting of s. 85(1) rollover where one party has elected a functional currency CRA indicated that where the parties to a s. 85 rollover transaction have different tax reporting currencies (as defined in s. 261(1)), it would require that two separate forms T2057 be filed. ...

16 June 2014 STEP Roundtable, 2014-0526591C6- STEP CRA Roundtable – June 2014 – Question 9-- summary under Subsection 156(1) Summary Under Tax Topics- Income Tax Act- Section 156- Subsection 156(1) relief for interest and penalties on deficient inter vivos trust instalments Does CRA assess instalment interest and penalties where an inter vivos trust has not made instalment payments required under s. 156? ...