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16 June 2017 External T.I. 2017-0698181E5- New principal residence rules & trusts-- summary under Subsection 40(6.1) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(6.1) s. 40(6.1) protected trust gain that accrued up to December 31, 2016 The estate of Deceased Parent, that qualified as a graduated rate estate (GRE) with a fiscal period of July 1, 2016 to June 30, 2017, sold the principal residence of the Deceased Parent in 2017 during that fiscal period at a gain. ... …[T]he transitional relief offered by proposed subsection 40(6.1) would be applicable in the scenario presented to any portion of the … gain that accrued up to December 31, 2016. ...

5 December 2022 External T.I. 2021-0915921E5- ELHT – Class of beneficiaries-- summary under Subparagraph 144.1(2)(e)(i) Summary Under Tax Topics- Income Tax Act- Section 144.1- Subsection 144.1(2)- Subparagraph 144.1(2)(e)(i) employee beneficiaries of a mooted EHLT form a single class if their benefit entitlements are reasonably similar A corporation (“Corporation”) operating a Canadian retail chain, and the over-1,000 stores that owned it settled a health and welfare trust (the “Trust”) providing health benefits to employees ol the Corporation (representing 22% of all employees under the Trust) and employees of Member stores and affiliates as to the balance. ... CRA responded: The term “class of beneficiaries” is defined in subsection 144.1(1) of the Act (for purposes of section 144.1 of the Act) as a group of beneficiaries with identical rights or interests under the trust. … [A] “right”, as it pertains to an ELHT, includes an entitlement to designated employee benefits (“DEBs”). ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) the forgivable loan portion of a CEBA loan is a s. 12(1)(x)(iv) receipt The Canada Emergency Business Account (“CEBA”) provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... This is also the case where the taxpayer made a subsection 12(2.2) election to reduce the paragraph 12(1)(x) inclusion in the year of receipt. … ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Gross Revenue Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Gross Revenue Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146(5) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(5) The payment of administration or management fees by an annuitant will constitute the payment of a premium to the RRSP. ...

1993 External T.I. 9335545 F- Sub — 256(2) and T2144-- summary under Subsection 256(2) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(2) Re RC's requirements for acceptance of a late-filed Form T2144. ...

16 August 1995 External T.I. 9512405- VESSELS- PARTIAL DISPOSITION & 13(16) ELECTION-- summary under Subsection 13(16) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(16) A partial disposition of a vessel will qualify as a disposition of a vessel for purposes of s. 13(16). ...

7 March 1997 External T.I. 9704665- NASDAQ & OTC BULLETIN BOARD-- summary under Regulation 3201 Summary Under Tax Topics- Income Tax Regulations- Regulation 3201 The Over-the-Counter Bulletin Board market in the United States is not a prescribed stock exchange, notwithstanding the ownership of that market by the National Association of Securities Dealers, Inc. ...

17 September 1997 External T.I. 9721415- INTERACTION OF SUBSECTION 55(2) & DIVIDEND REFUNDS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) The fact that a dividend refund has been received by the payor of a dividend is not normally relevant to consideration of the following expression: "that is not refunded as a consequence of the payment of a dividend to a corporation where the payment is part of the series of transactions or events". ...