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8 December 2003 Internal T.I. 2003-0042537 F- CIEE & SRAS-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) lay-off due to SARS did not qualify as an absence After taking leave in Canada in accordance with the terms of their employment regarding an offshore project, the employees’ return to the project was refused by the local authorities due to the intervening outbreak of the SARS epidemic, so that they were laid off for some time. ...

8 October 2004 Internal T.I. 2004-0093371I7 F- Crédit d'impôt à l'investissement & impôt minimum-- summary under Subparagraph 127(5)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(5)- Paragraph 127(5)(a)- Subparagraph 127(5)(a)(ii) carryback of ITCs from year where the taxpayer was subject to minimum tax After noting that where minimum tax applies in a particular taxation year (here, 2003), the deductible amount of investment tax credit in respect of property acquired in that year is limited under s. 127(5)(b) to the amount by which the tax otherwise payable under Part I for the year (2003) exceeds the minimum tax applicable to the individual for that year, the Directorate went on to note that the unused investment tax credit balance be carried back to previous years (2000 to 2002) if the investment tax credit amount is higher than this excess: for purposes of the carryback to such prior years, s. 127(5)(a)(ii) takes into account the balance that was not deductible in the particular taxation year (2003). ...

& Section 116116(5)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

7 January 2004 Internal T.I. 2003-0038217 F- gain en capital / résidence principale-- summary under Paragraph 45(1)(c) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(c) no partial change of use of residence where rental operation was not a business, or the business was ancillary A taxpayer constructed a housing unit for his son and son's spouse on the second floor of his personal residence and incurred small losses in renting it out to him. ...

7 January 2004 Internal T.I. 2003-0038217 F- gain en capital / résidence principale-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit rental of second floor of house to son at cost was not a business A taxpayer constructed a housing unit for his son and son's spouse on the second floor of his personal residence and incurred small losses in renting it out to him. ...

17 January 2025 Internal T.I. 2024-1029791I7 F- SSUC- Rémunération de la haute direction / CEWS--- summary under Executive Remuneration Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Executive Remuneration no adjustments are made to an eligible entity's Statement of Executive Compensation for NEOs filed pursuant to NI 51-102 for CEWS repayment purposes The Directorate found that the “executive remuneration” (as defined in para. ...

17 January 2025 Internal T.I. 2024-1029791I7 F- SSUC- Rémunération de la haute direction / CEWS--- summary under Subsection 125.7(14) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(14) repayment based on NI 51-102 statements, without adjustments Ss. 125.7(14) and (14.1) could require exchange-listed eligible entities to repay all or part of the CEWS they had received based inter alia on the excess of their executive remuneration over the 2019 base level. ...

& Section 116116(5)-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) no acquisition of property by the obligor corporation when its debt repaid or employee stock option exercised S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Subsection 20(12) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(12) no s. 20(12) deduction available where only a capital gain A deemed-resident s. 94 trust realized a capital gain and incurred gains tax of $10,000 for U.S. purposes on disposing in the U.S. of marketable securities but, for purposes of the Act, realized capital gains of only $20,000 (with Canadian tax thereon of $2,900) due to the securities' ACB previously having been stepped up under s. 128.1(1)(c). ...

8 July 2013 Internal T.I. 2012-0470021I7- Settlement of Future Benefits – ASO Plan-- summary under Subparagraph 39(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(a)- Subparagraph 39(1)(a)(ii) 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. ...