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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”). ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1) Unedited CRA Tags 250(1)(a) ART IV and XV REG 105 110(1)(f)(i) 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. ... We are not able to find any references in the case of R & L Food Distributors Ltd. 1 ("R & L") described in your letter that a "day" refers to each 24 hour period. ... Yours truly, for Director Reorganizations and Foreign Division Rulings Directorate Policy and Legislation Branch 1 R & L Food Distributors Ltd. v. ...

27 August 2012 External T.I. 2012-0438001E5- Taxable Benefits – Employer-Provided Vehicles Unedited CRA Tags 6(1)(a); 6(1)(e); 6(1)(k); 6(6) Principal Issues: 1. ... Baltkois August 27, 2012 Dear XXXXXXXXXX: Re: Taxable Benefits – Employer-Provided Vehicles We are writing in response to your email dated February 22, 2012, in which you asked whether an employee’s use of an employer-provided motor vehicle would give rise to a taxable benefit under the Income Tax Act (the “Act”) for various scenarios. ... Additional information on this subject is available in Interpretation Bulletin IT-63R5, Benefits, Including Standby Charge for an Automobile, from the Personal Use of a Motor Vehicle Supplied by an Employer- After 1992, Form RC18 – Calculating Automobile Benefits for 2011, and through the Automobile Benefits Online Calculator which is available on the CRA website. ...

19 February 2014 External T.I. 2013-0484761E5- Taxable Benefits – Employer-Provided Vehicles CRA Tags 6(1)(a) 6(1)(k) 6(1)(e) Principal Issues: Whether a taxable benefit would arise in connection with an employee's use of an employer-provided vehicle? ... Baltkois February 19, 2014 Dear XXXXXXXXXX: Re: Taxable Benefits – Employer-Provided Vehicles We are writing in response to your letter dated March 21, 2013, in which you asked whether an employee's use of an employer-provided vehicle would give rise to a taxable benefit under the Income Tax Act (the Act). ...

2013 Ruling 2013-0475701R3- MIC deemed interest & participating debt interest CRA Tags 212(1)(b) 214(3)(e) 212(3) "participating debt interest" Principal Issues: Whether a favourable ruling could be issued that the deemed interest payments paid to non-resident shareholders of a MIC would not fall within the meaning of PDI such that the payments would be exempt from Part XIII tax. ... XXXXXXXXXX 2013-047570 XXXXXXXXXX, 2013 Re: Advance Income Tax Ruling Request – XXXXXXXXXX Dear XXXXXXXXXX: This is in reply to your letter of XXXXXXXXXX, wherein you requested an advance income tax ruling on behalf of the XXXXXXXXXX (the "Corporation"). ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan CRA Tags 6(1)(f) 54 "capital property" 248(1) property 5(1) 6 39(1)(a)(iii) Principal Issues: 1. ... July 8, 2013 Trust Accounts Programs Division Income Tax Rulings Directorate Taxpayer Services and Debt Business and Employment Division Management Branch Kathryn McCarthy Attention: Marlene Sylvest 2012-047002 Settlement of Future Benefits – Administrative Services Only Plan We are writing in response to your e-mail of November 13, 2012, concerning an employer's group disability plan which is administered by an arm's length plan administrator ("administrator") on an administrative services only ("ASO") basis. ...