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16 November 2011 External T.I. 2011-0419191E5- Foreign Intermediaries & Canadian Owners-- summary under Subsection 215(6) Summary Under Tax Topics- Income Tax Act- Section 215- Subsection 215(6) breach of undertaking Where a foreign financial intermediary ("FFI") has represented to a Canadian financial institution ("CFI") that the beneficial owners of securities in a subaccount are eligible for a 0% rate of withholding based on Treaty exemptions and CFI later learns that there are Canadian beneficial owners in those accounts, CFI should withhold at a 25% rate as FFI has breached its undertaking to provide a replacement certificate which is accurate. ...

3 March 2015 External T.I. 2014-0519981E5 F- Donation avec charge / Gift with a charge-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property real estate property is one property Before considering the treatment under ss. 69(1)(b)(ii) and s. 69(1)(c) of a gift of a real estate property that is charged with a hypothec, CRA stated: [A]n immovable is normally considered as a single and unique property at least where such property is not the object of a legal partition into two or more distinct properties. ...

25 April 2014 External T.I. 2013-0515621E5 F- Frais de voyage / Travelling expenses-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) benefit where employer pays costs of friend to accompany employee on training trip An employee, who must undergo training outside the country, is allowed to be accompanied by a friend (who has no connection to the employer’s business) whose travel expenses (accommodation, airfare and meals) are paid by the employer. ...

3 June 2014 External T.I. 2014-0518911E5 F- Grand routier / long-haul truck-- summary under Long-haul truck Summary Under Tax Topics- Income Tax Act- Section 67.1- Subsection 67.1(5)- Long-haul truck weight reference is to loaded weight determined by manufacturer Does the gross vehicle weight rating refer to the loaded capacity and does it include the weight of a trailer? ...

29 April 2015 External T.I. 2014-0532691E5 F- Vente – immeuble- syndicat copropriétaire-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) distribution of gain to members of a condominium syndicate gave rise to a shareholder benefit After noting that a community of condominium owners is treated by s. 1039 of the Civil Code as a legal person, and is a corporation, CRA went on to indicate that when such a syndicate sold one of the condominiums at a capital gain and distributed the gain to its members then, as such members were deemed by the definition of “shareholder” in s. 248(1) to be shareholders, such distribution would give rise to a shareholder benefit. ...

3 March 2015 External T.I. 2014-0540051E5 F- Indiens – Intérêts d'une institution hors réserve-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 life annuity purchased off reserve did not qualify An Indian with a redacted connection to a reserve purchased a life annuity for a financial institution off reserve given that there was no financial institution on a reserve within 100 km of him. ...

5 July 2015 External T.I. 2015-0588201E5 F- Apportez vos appareils personnels / BYOD-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) fixed BYOD allowance not verified against receipts is taxable allowance CRA confirmed its view in 2014-0552731E5 that employees, who were required to use cell phones in the performance of their duties, received a taxable allowance when their employer paid them a fixed monthly amount (calibrated to each employee's duties) not in excess of their costs, given that the employer “did not require detailed receipts.” ...

22 December 2016 External T.I. 2015-0608201E5 F- Capital distribution from trust & NR4-- summary under Subsection 212(11) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(11) capital distributions other than of capital dividends not subject to Part XIII tax Although s. 212(11) deems all trust capital distributions to a non-resident beneficiary to be income distributions for Part XIII purposes, s. 212(1)(c) only imposes Part XIII tax on s. 104(13) income and capital dividend distributions. ...

21 January 2009 External T.I. 2008-0266191E5 F- Part IV & Capital Gain Strip-- summary under Paragraph 186(1)(b) Summary Under Tax Topics- Income Tax Act- Section 186- Subsection 186(1)- Paragraph 186(1)(b) 943963 Ontario followed CRA confirmed its position in 9711005 and indicated that its position in 9906255 was no longer valid because of the 943963 Ontario decision. ...

20 October 1997 External T.I. 9715265- INTERACTION OF SUBSECTION 212(11) & PARAGRAPH 212(1)(C)-- summary under Subsection 212(11) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(11) "In our view, subsection 212(11) of the Act merely characterizes any amount paid or credited by a trust or estate as income of the trust or estate for the purposes of paragraph 212(1)(c) of the Act. ...