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7 July 2003 External T.I. 2001-0091415 F- Income & Losses from Bus. or Prop. ... For example, if a 30 year old Buyer died at age 75, the site could only be used for 54 additional years until the 99 th anniversary of the agreement – at which point the remains would be removed and buried (unless the agreement was renewed). ...

7 July 2003 External T.I. 2001-0091415 F- Income & Losses from Bus. or Prop. ... For example, if a 30 year old Buyer died at age 75, the site could only be used for 54 additional years until the 99 th anniversary of the agreement – at which point the remains would be removed and buried (unless the agreement was renewed). ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subsection 12(2.2) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(2.2) s.12(2.2) election can be made re s. 12(1)(x)(iv) inclusion for forgivable CEBA loan The Canada Emergency Business Account (“CEBA”) program provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... A taxpayer not qualifying for the 25% forgiveness who settles the loan for 100% of the principal may generally claim a deduction under s. 20(1)(hh) equalling the previous s. 12(1)(x) inclusion – even where the taxpayer made the s. 12(2.2) election. ...

15 March 2019 External T.I. 2018-0766021E5- Obligation to prepare T4A slips-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt the payer is the person who has discretion and control over the funds A Canadian university agreed with a (perhaps, foreign) Ministry to apply funding received by it to pay the tuition of and a monthly stipend to trainees who were accepted into a University program. ...

7 November 2022 External T.I. 2022-0926091E5- Transfer of UK DB pension benefits to a UK SIPP-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt doctrine applied to direct payment from one UK pension plan to UK individual pension plan After a UK resident (under age 55) became resident in Canada, the commuted value of the individual’s member benefits under a UK defined-benefit pension plan was transferred directly to a UK self-invested personal pension plan (SIPP) of which the individual was the sole beneficiary. ...

15 June 2015 External T.I. 2014-0525501E5- Royalty payments & the US or UK Treaties-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 fees paid to the U.S. or U.K. for access to customer lists were exempt royalties Canadian-resident UserCos, who use existing confidential lists of the names and addresses of customers who have purchased certain types of products (“Lists”) for marketing purposes, pay CanCo fees based upon their use of the Lists. ... Turning first to the US Treaty, CRA stated: [T]here has not been a transfer of ownership of the information, but simply permission has been granted to use the information on the Lists for an approved purpose…[so that] the payment can be said to be “for the use of or the right to use…” the information on the Lists. … [T]he OwnerCos have information in their possession due to their special knowledge and experience and there is little that needs to be done to meet the request by CanCo to provide the Lists. ... Therefore… the Lists constitute “information concerning industrial, commercial or scientific experience”…. … CanCo (the payer) is a resident of Canada and therefore, it is our view that the payment arose in Canada. ...

6 December 2012 External T.I. 2012-0461711E5 F- Paiements indirects / Indirect payments-- summary under Subsection 200(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(1) no T4A slip to be issued by producer paying mandatory contributions to the fund for the union of the artist whose corporation receives fees from the producer A producer who retains the services of an incorporated performing artist is required to pay a percentage of the fees otherwise payable by it to the artist’s Corporation (respecting the services performed by the artist as an employee of the Corporation) directly to the benefits plan (the “CSA”) for the Union des Artistes (UDA). ... In that event, a T4A slip would not be issued by the producer to the Corporation or the Taxpayer respecting the mandatory contribution. …. ...

30 January 2014 External T.I. 2013-0515761E5 F- Dividend received-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt book entries merely record and do not establish that a dividend was paid A dividend of a taxable Canadian corporation owned by an individual is not paid in money but is recorded in its books as an increase in a loan owing to the shareholder or as a decrease in a loan made to the shareholder. ...

7 July 2016 External T.I. 2015-0595481E5- Ontario Corporate Minimum Tax – Forgiven Debt-- summary under Clause 54(2)(b) Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Taxation Act 2007- Section 54- Subsection 54(2)- Clause 54(2)(b) forgiven amount included in adjusted net income A corporation has a forgiven amount which it applies federally under the s. 80 rules but results in net income for financial statement purposes, causing a Corporate Minimum Tax liability under the Taxation Act, 2007 (“TA”). ... Therefore, if GAAP determines that an economic gain arising on a forgiven amount is to be included in a corporation’s net income or net loss, then the forgiven amount will also be included in [adjusted net income or net loss] for purposes of subsection 54(2) of the TA. … Further additions or deductions (“adjustment(s)”) to ANI/ANL are permitted if prescribed in section 9 of Regulation 37/09 of the TA. ...

30 March 2011 External T.I. 2010-0390591E5 F- Cotisation spéciale-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amounts paid by set-off are both paid even though no movement of funds All the condo owners in a condo complex that was used only in a high-end commercial accommodation business leased their units to a manager for a share equalling 50% of the aggregate rental income (but with the municipal taxes and condominium fees for common services continuing to be borne by the co-owners directly). ...