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Technical Interpretation - Internal summary

1 May 2017 Internal T.I. 2015-0624511I7 - 248(1)(e)(ii) of the definition of TCP -- summary under Paaragraph 94(3)(c)

However, recognizing an upstream loan would result in double counting because the assets acquired by the parent out of the proceeds thereof would already be counted for purposes of the tests so that the loan’s value decreases the relevant FMV of the shares of the particular wholly-owned subsidiary. ...
Technical Interpretation - Internal summary

2 September 2009 Internal T.I. 2009-0329251I7 F - Application du paragraphe 80(16) -- summary under A

The Directorate confirmed the TSO approach, which was to designate pursuant to s. 80(16) the maximum amounts permitted under ss. 80(7) and (11), so that the forgiven amount would be applied first against the balance of the non-capital loss, second as to reduce ¾ of the cumulative eligible capital and third, to reduce the adjusted cost base of the related corporation shares under s. 80(11), resulting in an amount being deemed to be a capital gain from the disposition of capital property under s. 80(12). ...
Technical Interpretation - Internal summary

14 January 2010 Internal T.I. 2009-0323991I7 F - Débenture échangeable et opération à terme -- summary under Paragraph 20(1)(f)

14 January 2010 Internal T.I. 2009-0323991I7 F- Débenture échangeable et opération à terme-- summary under Paragraph 20(1)(f) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(f) only ½ deduction under s. 20(1)(f)(ii) for premium paid on cash-settling an exchangeable debenture under pre-2010 policy, and no s. 20(1)(f) deduction for cash settlement of forward A predecessor of the taxpayer had issued an exchangeable debenture exchangeable into share of a corporation (“Corporation 2”) of which the taxpayer was one of the shareholders. ...
Technical Interpretation - Internal summary

21 December 2009 Internal T.I. 2008-0296131I7 F - Fraction à risque -- summary under Paragraph 96(2.2)(c)

To the extent that these entities are related subsection 96(2.2)(c) would not be applicable for the purpose of reducing Canco's at-risk amount to the extent that the various borrowings have a legitimate business purpose and are not related to the acquisition of Canco's interest in USLP. ...
Technical Interpretation - Internal summary

13 January 2010 Internal T.I. 2009-0334931I7 F - Demande de changement d'exercice -- summary under Subsection 249.1(7)

After noting that, in light of s. 249.1(3), this entailed a request for an amendment retroactive to the end of the previous fiscal year ending February 27, 2007, the Directorate stated: In general, a request for a change of fiscal year will be approved if it can be shown that the request is motivated solely by valid business reasons ….. ...
Technical Interpretation - Internal summary

2 February 2010 Internal T.I. 2009-0345741I7 F - Programme d'aide financière d'urgence ("PAFU") -- summary under Paragraph 56(1)(u)

. Since the PAFU is primarily intended to meet the needs of people affected by an emergency situation, we believe that the financial assistance that will be paid by the MESS in the form of a lump sum to cover living expenses and/or specific costs will be paid after a review of needs by the MESS, without the MESS conducting a means or income test for people affected by an emergency situation. ...
Technical Interpretation - Internal summary

22 December 2009 Internal T.I. 2009-0343331I7 F - Determination of CCPC Status -- summary under Canadian-Controlled Private Corporation

Consequently, there is no provision in provincial legislation affecting Part IA corporations for the power of the majority shareholder to control the election of the board of directors to be limited or altered by means of a USA. ...
Technical Interpretation - Internal summary

10 January 2008 Internal T.I. 2007-0254551I7 F - Provision relative à certaines marchandises -- summary under Subparagraph 20(1)(m)(i)

The fact that the franchisor does not itself deliver the goods does not invalidate the application of subparagraph 20(1)(m)(i) ...
Technical Interpretation - Internal summary

11 October 2017 Internal T.I. 2017-0719181I7 F - Agreement in writing -- summary under Paragraph (g.4)

11 October 2017 Internal T.I. 2017-0719181I7 F- Agreement in writing-- summary under Paragraph (g.4) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (g.4) pre-production mine development expenses that qualify under CEE (g.4) need not qualify under (g.3) Corporation X, which is a principal-business corporation, issues a flow-through share under a written agreement entered into on December 31, 2012, renounces its Canadian exploration expenses under the look-back rule and enters into a written agreement dated June 20, 2013 with a subcontractor for the incurring of pre-production mine development expenses, with the work (entailing payments of Corporation X of $2 million) ending on December 31, 2013. ...
Technical Interpretation - Internal summary

24 October 2006 Internal T.I. 2006-0203901I7 F - Avantage automobile -- summary under Paragraph 6(1)(a)

. In finding that this exception to a taxable benefit was inapplicable, CRA stated: According to the CRA, a pick-up point is a common place specifically designated by the employer for that purpose to which all employees must go. ...

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