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14 March 2003 Internal T.I. 2003-0182977 F - 40(3.5)(c) -- summary under Paragraph 40(3.5)(c)

". Words and Phrases apply ...

10 March 2003 Internal T.I. 2002-0172187 F - DEDUCTIBILITE DES INTERET -- summary under Dividend

. … Consequently, you cannot characterize this amount as a non-deductible dividend to the corporation. ...

17 January 2019 Internal T.I. 2018-0781041I7 - Non-resident trust ceasing to be deemed resident -- summary under Subsection 94(5)

This corrects 2013-0509111E5.

CRA stated: [P]aragraph 94(2)(t) … applies to expunge the contribution after the time of the sale (i.e., from the time of the sale forward, the contribution is considered to have never occurred). ...

8 June 2018 Internal T.I. 2017-0683021I7 - Assignment of capital interest in a trust -- summary under Subsection 107(5)

., were subject to Part XIII tax under s. 212(1)(c) Similarly, “the transfer of the Trust’s assets to ULC … was for the benefit of Y and Z,” and s. 107(2.1) thereby applied to deem them to be disposed of for fair market value proceeds. ...

8 June 2018 Internal T.I. 2017-0683021I7 - Assignment of capital interest in a trust -- summary under Subsection 56(2)

If Y and Z argued that s. 104(13) did not apply to them because no amount was payable to them in the year, CRA would apply s. 56(2) or (alternatively) s. 105(1) to include the dividend amounts in their income – but without any s. 104(6) deduction to the Trust. ...

4 April 2019 Internal T.I. 2017-0736531I7 - Articles IV(6) and X(6) of the Canada-US Treaty -- summary under Article 10

IV(6) – and, similarly, LLC1 Itself would be considered to be deriving such income as a qualifying person if it had chosen to be treated as a corporation. ...

13 August 2018 Internal T.I. 2018-0763611I7 F - Subpar 152(4)(b)(iii) and FAPI -- summary under Subaragraph 152(4.01)(b)(iii)

. … [T]he reassessments would be attributable to FAPI arising directly from the contribution by the Taxpayer of the Marketable Securities to ForeignCo which, in our view, would be a "transaction" between Holdco and ForeignCo referred to in subparagraph 152(4)(b)(iii) that it would be reasonable to consider as relating to the reassessments for purposes of subparagraph 152(4.01)(b)(iii). ...

1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement -- summary under Paragraph 7(3)(b)

Before addressing whether such payments were deductible under s. 32.1 or 9, the Directorate stated: [P]aragraph 7(3)(b) does not apply to prohibit a deduction for Canco’s PSP expenditures ….. ...

1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement -- summary under Income-Producing Purpose

. … [A]mounts invoiced by Parentco to a particular entity are based on the employee’s employer as at the grant date. ...

14 January 2020 Internal T.I. 2018-0785991I7 F - Subsection 86.1(2) -- summary under Subsection 86.1(2)

. … Furthermore, to the extent that the conditions in paragraphs 86.1(2)(e) and (f) have been satisfied and the Distribution was made in respect of all of the Common Shares of the capital stock of Parentco owned by the particular taxpayer at the time of the Distribution, it is our view that the Distribution is an eligible distribution to that taxpayer within the meaning of subsection 86.1(2). ...

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