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17 June 2014 External T.I. 2013-0506731E5- Immigration-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt note satisfied dividend An individual shareholder immigrates to Canada, thereby becoming a Canadian resident. ...

17 February 2004 External T.I. 2003-0033915- Cash pooling- shareholder benefit-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no automatic set-off In indicating that a cash pooling arrangement entered into by a Canadian subsidiary with its non-resident parent corporation could result in an income inclusion under s. 15(2), Revenue Canada indicated that its review of the jurisprudence on s. 15(2) suggested that debts between a shareholder and a particular corporation do not generally offset for purposes of determining either whether the shareholder became indebted to the corporation in the first place, or whether that indebtedness has been repaid. ...

10 April 2024 External T.I. 2021-0919231E5- Foreign tax allocation to a partner-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment by partnership of withholding tax treated as a distribution to its partners Regarding the allocation of foreign tax by a partnership to a partner, CRA stated: If the partnership pays the foreign tax on behalf of the partner or the foreign tax is withheld on behalf of the partner in accordance with foreign law from the foreign income paid to the partnership, such amount would be considered [for purposes of s. 53(2)(c)(v)] to be received by the partner on account or in lieu of payment of, or in satisfaction of, a distribution of the partner’s share of the partnership profits or partnership capital. ...

13 November 2014 External T.I. 2014-0535041E5 F- Bien de remplacement – Location d'immeubles-- summary under Paragraph 44(5)(a.1) Summary Under Tax Topics- Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(a.1) rental property use before and after satisfies test A couple who co-owned various rental properties received insurance proceeds on the complete destruction of one of the properties, and purchased chalets in a resort area for rental use. ... CRA responded (TaxInterpretations translation): Even though the physical characteristics of the new properties would not be identical to those of the previous properties, the properties appear to be of the same nature (rental properties) and to be put to the same use (rental). … [T]he use made by the taxpayers of the new properties can be considered as an identical or similar use as they made of the previous property, for purposes of paragraph 44(5)(a.1). ...

16 November 2015 External T.I. 2015-0595041E5- Mutual Fund Trusts & 108(2)(a)(i)-- summary under Paragraph 108(2)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(2)- Paragraph 108(2)(a) MFT that is redeemable on demand for securities' (and s. 108(2)(a)) purposes with 2 redemption windows annually Where a provincial securities commission has a policy on what it considers to be redeemable on demand, will CRA generally accept such policy in determining whether the redeemable-on-demand requirement in s. 108(2)(a)(i) is satisfied? CRA responded: [W]here a provincial securities commission has a policy concerning what it considers to be redeemable on demand for provincial securities purposes [CRA]…will generally accept such policy in determining whether a particular trust would satisfy the redeemable on demand requirement in subparagraph 108(2)(a)(i). …. ...

7 December 2010 External T.I. 2010-0363431E5 F- Date limite cotisation REER-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt RRSP premium “paid” when cheque received by issuer, not when it’s deposited In commenting on whether an RRSP premium is considered to have been paid within the first 60 days of a year, CRA stated: In general, we consider a premium to have been paid on or before the 60th day after the end of the calendar year if the RRSP issuer received a cheque for an RRSP contribution on or before the 60th day, and the date of the cheque is also on or before the 60th day. ...

20 June 2006 External T.I. 2005-0149651E5 F- CEE / FEC-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) expenditures to ensure safety of exploration personnel generally qualify if not specifically excluded The results of preliminary exploration work indicated that further exploration of the “Property” was warranted – but this would require work on the Property to make it safer before geologists could perform the additional work. ...

28 September 2006 External T.I. 2006-0197841E5 F- Shareholders agreement & 256(1.4)-- summary under Subparagraph 251(5)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b)- Subparagraph 251(5)(b)(i) technically a contingent right to acquire control where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares Four unrelated individuals (A, B, C and D) each hold 25% of the shares (being common shares) of Opco through their respective wholly-owned holding companies (Aco, Bco, Cco and Dco). ... After referencing IT-64R4, para. 37, CRA stated: It appears to us that subsection 256(1.4) would technically apply in the situation described …. ...

19 October 1999 External T.I. 9925055- GAINS & LOSSES ON OPTIONS-- summary under Options Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ... The trust in such an arrangement is a separate person for income tax purposes and therefore a stock call written outside an RRSP … would constitute a naked option. ...

1 August 1996 External T.I. 9604555- AMOUNT PAYABLE SUBSECTION 104(24)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note normally only constitutes an enforceable right to the income where it is payable on demand Regarding whether a mutual fund trust beneficiary had a legal entitlement to the income of the trust where a promissory note for the income amount was issued to the beneficiary, RC stated: [O]rdinarily a promissory note is given and received as acknowledgement of the existence of and/or the conditional payment of a debt and does not itself create the debt. ...