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9 June 1997 Income Tax Severed Letter 9714705- Twenty one year rule — see 970488 Unedited CRA Tags 104(4), 159(6.1) SUMMARY: 21-year rule – see ^CAIXRCV 970488—ITA-104(4), 159(6.1)—Response to taxpayer request to amend the Income Tax Act to grandfather certain pre-1972 trusts from the 21-year deemed realization rule in subsec. 104(4) of the Income Tax Act. ... REASONS: Taxpayer has option to apply to provincial court to have the trust varied & property distributed under 107(2); alternatively subsection 159(6.1) allows trusts election to spread payment of taxes arising on deemed disposition over 10 years charging interest at the prescribed rate. 971470 XXXXXXXXXX L. ...

The following is a brief summary of the guideline: • The funder must be a principal in the new business to be carried on in the year. It must be legally possible for a funder to carry on such a business as a principal. • The funder must have rights to commercially exploit any resulting products and/or processes. However, a funder may license the right to use to another party in exchange for a share of gross or net revenue for an unlimited term or a term approximating the expected useful life of the resulting product or process. • The proportionate share of revenue to the funder must represent a reasonable expectation of profit. • The funder must not be guaranteed a return of his principal and/or revenue. ...

25 July 1989 Income Tax Severed Letter AC74066- Refundable Investment Tax Credit on SR & ED Expenditures- Qualifying Corporation July 25, 1989 W.A. ... Nanner Subject: Qualifying Corporation Subsection 127.1(2) of the Act File: 7-4066 We are writing in reply to your memorandum of June 26, 1989, wherein you requested our comments on whether the partners of a partnership that conducts scientific research and experimental development ("SR & ED") are entitled to the refundable investment tax credit ("RITC") in respect of the SR & ED expenditures meet the requirements of section 37 and subsection 127(9) of the Income Tax Act (the "Act") and that the partners are not "specified members" of the partnership as defined in section 248(1) of the Act. ... In our opinion, there is no RITC available under subparagraphs (a)(vi) and (vii) of the definition of RITC in respect of the SR & ED expenditures incurred by a partnership and allocated to a partner that is qualifying corporation. ...

14 November 2007 External T.I. 2007-0255831E5- Medical expenses,travel & lodging,heart transplant Unedited CRA Tags 118.2(2)(g) 118.2(2)(h) 118.2(2)(l.1) Principal Issues: Patient & spouse travelled 400 km for heart transplant; rented basic studio condo near hospital for 3 mths. Asked whether vehicle, food & lodging expenses qualify as a medical expenses and whether flat per km and per meal rates can be used without receipts. ...

15 May 2019 Internal T.I. 2019-0803411I7- Medical practitioners- the METC & the DTC Unedited CRA Tags 118.4(2); 118.3(a.2) and 118.3(a.3) Principal Issues: Whether the CRA can set up a process to consider requests to change (or expand) the categories of medical practitioners who can certify Form T2201, Disability Tax Credit Certificate. ... Reasons: Changes to the categories of medical practitioners who can provide certification for the purpose of the disability tax credit (DTC) would require a legislative amendment to section 118.3 – this is beyond the CRA's mandate as an administrator of the Act. ... Medical practitioners for the purposes of the DTC While subsection 118.4(2) describes the requirements for a person to be considered a medical practitioner for purposes of sections 118.2 and 118.3 (among others) – namely, the requirement to consider the relevant provincial legislation – specific rules in section 118.3 allow only certain categories of medical practitioners to certify that an individual has a severe and prolonged impairment in physical or mental functions for the purposes of the DTC. ...

11 August 2003 External T.I. 2002-0176465- QFP USED BY INLAWS & DEATH OF SPOUSE Also released under document number 2002-01764650. ... You referred to the situations in documents # 2000-0027385 (the "First Document") and # 2000-0052385 (the "Second Document") and asked for clarifications regarding the farming revenue and use tests in the definition of "qualified farm property" ("QFP") in subsection 110.6(1) of the Income Tax Act (the "Act"). ...

A recent audit revealed that capital tax returns should have been prepared for both 92 & 93. The taxpayer corporation contends that the department is unable to assess 92 & 93 since they are now statute-barred. ... Reasons FOR POSITION TAKEN: Section 181.6 & 190.2 establish the filing dates for purposes of Part I.3 and VI respectively. ...

8 June 2018 Internal T.I. 2018-0744881I7- Regulation 403 – allocation of income Unedited CRA Tags 138, 248 (definition of insurance corporation), Regulations 400 and 403 Principal Issues: For the purposes of taxable income allocation under Regulation 403, should the taxpayer ignore the PEs of the partnerships in which the taxpayer is a partner? ... & Investigations Branch Lata Agarwal, CPA, CMA, MBA 2018-074488 Provincial income allocation – permanent establishments of insurance corporation We are writing in response to your email dated February 20, 2018, in which you have asked us to confirm the CRA’s position stated in technical interpretation (“TI”) E56239 that each member of a partnership has a permanent establishment (“PE”) in the province in which the partnership has a PE. Your email describes a corporate taxpayer that filed Form T2 Schedule 5, Tax Calculation Supplementary – Corporations, for its XXXXXXXXXX taxation year, as an insurance corporation under section 403 of Part IV of the Income Tax Regulations (the “Regulations”). ...

26 May 2010 External T.I. 2009-0342121E5- rooftop solar panels & class 43.2 Principal Issues: 1.will rooftop solar panels & equip qualify for inclusion in class 43.2 under various scenarios subject to the specified energy rules limiting CCA. 2.will claiming cca jeopardize the principal residence exemption? Position: 1.provided expenses incurred for the purpose of producing income & other conditions of the class are met; 2. the principal residence claim will not be jeopardized provided no cca claim is made on the building itself & the earning of income is ancillary to the residence use. Reasons: 1. 1102, 1100(25); 1100; 2.45(2) & IT120-r6 XXXXXXXXXX 2009-034212 Lena Holloway May 26, 2010 Dear XXXXXXXXXX: Re: Technical Interpretation Request regarding Capital Cost Allowance of Solar Panels This is in response to your facsimile correspondence of September 24, 2009 requesting our views as to the income tax treatment of the purchase of solar photovoltaic systems under various hypothetical scenarios. ...

16 November 2020 External T.I. 2020-0864141E5- TI – Tax Treatment of Loan Forgiveness under CEBA Unedited CRA Tags 12(1)(x); 12(2.2); 80 * Principal Issues: What is the tax treatment of forgiveable portion of a loan granted under the CEBA program? ...