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30 September 2013 Internal T.I. 2012-0439661I7- Income earmarked for future use & 95(2)(a)(i)-- summary under Subparagraph 95(2)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(i) funds earmarked for future projects of sister affiliates A CFA of Canco held funds generated from projects which were owned and operated by FA1, with the funds being "earmarked" for future investment in projects to be carried out by other CFAs of Canco. ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C)-- summary under Subsection 91(5) Summary Under Tax Topics- Income Tax Act- Section 91- Subsection 91(5) upward ACB adjustment to the CFA occurring as a result of recognized FAPI under the old s. 94(1) rules represented basis that could be distributed while the trust was subject to the new s. 94(3) trust rules A non-resident discretionary trust (“NRT”) owned all the shares of CFA. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Paragraph 8(b) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 8- Paragraph 8(b) property does not satisfy the “solely” test in Class 8(b) where it was necessary for the proper functioning of the building The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(5) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(5) building shell was a building or structure/ addition refers to extension of structure The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Paragraph 5907(1.3)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1.3)- Paragraph 5907(1.3)(a) overview of FAT rules re consolidated US return with R&D credit Four U.S. ...

The mid-amble of subsection 13(29) … clearly indicates that the taxpayer must file a single election with its return for the “particular year” …. Once the Long-Term Project election has been filed with its return for the particular year, subsection 13(29) will apply in respect of the taxpayer’s “inclusion year” … [which g]enerally … will be the third and subsequent taxation years of the project where the taxpayer owns project property in that taxation year that has not yet otherwise become available for use. … … The … current … Form T1031 suggests that the form must be filed annually. … Form T1031 is currently under review. ...

3 July 2019 Internal T.I. 2019-0791521I7- Tuition tax credit- University outside Canada-- summary under Subparagraph 118.5(1)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 118.5- Subsection 118.5(1)- Paragraph 118.5(1)(b)- Subparagraph 118.5(1)(b)(i) CRA will follow Fortnum in “factually similar” situations In response to a request as to its interpretation of s. 118.5(1)(b) following Fortnum, CRA first noted that, regarding the attendance of the taxpayer in that case at a 10- week summer semester consisting of 11 courses each of one or two weeks’ duration, “the court applied the three consecutive week requirement to the summer semester as a whole, rather than to each individual course in the semester,” and then stated: Our interpretation of subparagraph 118.5(1)(b)(i) … as explained in paragraph 2.10 of … S1-F2-C2.. has generally not changed as a result of … Fortnum. … [T]his case was heard … under the Informal Procedure … [and] do[es] not have precedential value. ...

Our position is supported by … Berkovic … 83 DTC 335 and …. Mitosinka …. ...

17 April 2003 Internal T.I. 2003-0181507 F- PRET SANS INTERET-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) accessing the exceptional circumstances test requires demonstrating “a sufficient connection between the interest-free loan and an indirect source of the person's income” After surveying the jurisprudence on the exceptional circumstances test, the Directorate stated: Interest deductibility in other situations involving interest-free loans by a person to a corporation of which the person is not a shareholder may be justified on the particular facts of the case, as in Canadian Helicopters … and … Byram … to the extent that the person can show that there is a sufficient connection between the interest-free loan and an indirect source of the person's income. ...

. … Furthermore … the favourable tax results … are similar … to those available under the employee stock option rules …. even though … the requirements of paragraph 110(d) or (d.1) are not satisfied. ...