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10 May 2001 Internal T.I. 2001-0065827 F- FINES + PENALTIES- INTÉRETS ET PÉNALITÉS-- summary under Paragraph 18(1)(t) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(t) s. 18(1)(t) enacted for greater certainty CRA noted that Ioegen (96 DTC 1993) found that s. 18(1)(t) was enacted for greater certainty. ...

14 March 2013 Internal T.I. 2012-0451131I7- Trustee's Rights & Obligations under the Act-- summary under Paragraph 241(4)(k) Summary Under Tax Topics- Income Tax Act- Section 241- Subsection 241(4)- Paragraph 241(4)(k) The Minister may disclose information respecting the bankrupt to the trustee in bankruptcy without a T103 given that the trustee is deemed to be the bankrupt's agent by s. 128, and the trusteee is entitled to taxpayer information under s. 164(1) of the Bankruptcy and Insolvency Act. ...

8 November 1996 Internal T.I. 9635527- INTERACTION SECTION 216 & SECTION 188.94-- summary under Section 118.94 Summary Under Tax Topics- Income Tax Act- Section 118.94 Even though Part XIII tax is levied on the gross amount of a particular payment, for the purpose of calculating a non-resident's world income such amount is reduced by applicable expenses. ...

8 November 1996 Internal T.I. 9635527- INTERACTION SECTION 216 & SECTION 188.94-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) "The filing of a return of income pursuant to section 216 cannot have any impact on whether or not an individual meets the 'all or substantially all' test in section 118.94. ...

28 April 1994 Internal T.I. 9331017- TERMINAL LOSSES & LOSS OF TAX EXEMPT STATUS-- summary under Subsection 149(10) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(10) A terminal loss in the year of change from exempt to taxable status is deductible. ...

30 September 1994 Internal T.I. 9414527- BORROWINGS & EXCESS INSURANCE COLLATERAL-- summary under Paragraph 20(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.2) Where the life insurance coverage under an assigned policy is $500,000 and the average balance owing under the borrowing is $200,000, the amount deductible under s. 20(1)(e.2) is limited to 40% of the lesser of the premiums payable and the net cost of pure insurance under the policy for the year. ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) "For purposes of Part I.3, and with respect to leases, it is the department's position that it is the legal nature of the agreement that governs irrespective of the accounting treatment or nomenclature used to describe or characterize the related transaction(s). ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) The obligation of a purchaser under a conditional sales agreement generally will be included in its capital only where such obligation has been outstanding for more than 365 days, unless the obligation is evidenced by the issuance by it to the vendor of a note. ...

22 February 1996 Internal T.I. 9604507- PART I.3- CAPITAL LEASES & CONDITIONAL SALES AGREEMENTS-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) A lease obligation reflected as an asset on the balance sheet of a lessor corporation is not eligible for an investment allowance as a loan or advance. ...

11 October 2013 Internal T.I. 2013-0475761I7- Deadline for filing a waiver of tax credit – ORDTC-- summary under Subsection 152(4) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4) waiver of credit after return due date A corporation filed its original 2011 T2 return somewhat after the filing due date, and then requested an adjustment to amend the return by waiving the full amount of the previously-claimed Ontario Research and Development Tax Credit. ...