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7 December 2010 External T.I. 2010-0363431E5 F- Date limite cotisation REER-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt RRSP premium “paid” when cheque received by issuer, not when it’s deposited In commenting on whether an RRSP premium is considered to have been paid within the first 60 days of a year, CRA stated: In general, we consider a premium to have been paid on or before the 60th day after the end of the calendar year if the RRSP issuer received a cheque for an RRSP contribution on or before the 60th day, and the date of the cheque is also on or before the 60th day. ...

16 January 2017 Internal T.I. 2016-0651411I7- Reassessment period – transfer pricing-- summary under Subparagraph 402(3)(a)(i) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3)- Paragraph 402(3)(a)- Subparagraph 402(3)(a)(i) reallocation of gross revenue consequential on s. 247(2) assessment A s. 247(2) transfer-pricing adjustment (“TPA”) was reassessed by CRA within the three years after the normal reassessment period to increase the sales proceeds on a cross-border sale. ... The Directorate found that CRA was also authorized by s. 152(4)(b)(iii) to reassess so as to reallocate both the pre-TPA and additional TPA revenue among the provinces – apparently even though this might only affect relative provincial taxable income and not affect federal taxable income (given that the TPA reassessment had already occurred). ...

21 July 2009 Internal T.I. 2009-0322591I7 F- Déduction des intérêts-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt replacement of note with capitalized note with note for full amount did not constitute payment by novation The taxpayer purchased assets from the vendor (apparently, a non-resident) in consideration for shares of the taxpayer and interest-bearing debt, that was evidenced by a note providing that unpaid interest could be added to the principal of the note. ...

9 May 2006 Internal T.I. 2006-0176371I7 F- Bourses d'études ou d'entretien-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt bursaries “received” by students even though required to be applied directly to their loans CRA found that bursaries paid to Quebec students under the Program québécois de prêts et bourses (the Quebec loans and bursaries program) by converting loans initially made to them into bursaries (following an ARQ verification of their income) that, thus, did not have to be repaid, were includible in income under s. 56(1)(n), subject to the exclusions under s. 56(3). ...

20 June 2006 External T.I. 2005-0149651E5 F- CEE / FEC-- summary under Paragraph (f) Summary Under Tax Topics- Income Tax Act- Section 66.1- Subsection 66.1(6)- Canadian exploration expense- Paragraph (f) expenditures to ensure safety of exploration personnel generally qualify if not specifically excluded The results of preliminary exploration work indicated that further exploration of the “Property” was warranted – but this would require work on the Property to make it safer before geologists could perform the additional work. ...

28 September 2006 External T.I. 2006-0197841E5 F- Shareholders agreement & 256(1.4)-- summary under Subparagraph 251(5)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b)- Subparagraph 251(5)(b)(i) technically a contingent right to acquire control where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares Four unrelated individuals (A, B, C and D) each hold 25% of the shares (being common shares) of Opco through their respective wholly-owned holding companies (Aco, Bco, Cco and Dco). ... After referencing IT-64R4, para. 37, CRA stated: It appears to us that subsection 256(1.4) would technically apply in the situation described …. ...

19 October 1999 External T.I. 9925055- GAINS & LOSSES ON OPTIONS-- summary under Options Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. ... The trust in such an arrangement is a separate person for income tax purposes and therefore a stock call written outside an RRSP … would constitute a naked option. ...

1 August 1996 External T.I. 9604555- AMOUNT PAYABLE SUBSECTION 104(24)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note normally only constitutes an enforceable right to the income where it is payable on demand Regarding whether a mutual fund trust beneficiary had a legal entitlement to the income of the trust where a promissory note for the income amount was issued to the beneficiary, RC stated: [O]rdinarily a promissory note is given and received as acknowledgement of the existence of and/or the conditional payment of a debt and does not itself create the debt. ...

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). ...