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HEALTH & SAFETY ACT) Unedited CRA Tags 18(1)(a) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: Is a fine imposed under the Occupational Health & Safety Act deductible in computing business or property income? ... Azzi December 19, 1995 Dear Sir: Re: Deductibility of Fines or Penalties This is in reply to your letter of October 10, 1995, wherein you request our views as to the deductibility of a fine imposed under the Occupational Health & Safety Act. ...

STEP CRA Roundtable – June 18, 2015 Question 14. Requirements for Question #6 on page 2 of the T3 Return Question 6 of the T3 return reads as follows: Did the trust borrow money, or incur a debt, in a non-arm's length transaction since June 18, 1971? ... The instructions for question 6 refer the reader to Interpretation Bulletin IT-406R2 – Tax Payable by an Inter Vivos Trust (the "IT"). ... Reference may be made to Folio S1-F5-C1 – Related persons and dealing at arm's length, for discussion as to the meaning of the term "at arm's length". ...

LLPs & LLLPs CRA Tags 248(1) "corporation" Principal Issues: Whether LLPs and LLLPs governed by the laws of Florida or Delaware would generally be treated as corporations for the purposes of the Act? ... Reasons: The provisions of the foreign legislation and the articles creating these entities support the general conclusion that these types of entities should generally be treated as corporations for the purposes of the Act. 2016 International Fiscal Association Conference CRA Roundtable Question 1 – Entity Classification: U.S. ... The main factors we considered in our analysis of these entities are the existence of a separate legal personality that is recognized under the law of the relevant foreign jurisdiction – meaning the full legal capacity to acquire and own property, to sue and be sued, to carry on their own activities and to incur liabilities of their own – and the extensive limitation of liability afforded to all of their members. ...

8 November 2022 Internal T.I. 2022-0942701I7- RCMP cadet training – service buyback Unedited CRA Tags 5, 6, 147.1(11), 8501(2), 8503(3)(a)(i) Principal Issues: In the circumstances, is the period of cadet training completed by an RCMP cadet eligible service for purposes of subparagraph 8503(3)(a)(i) of the Regulations? ... November 8, 2022 HEADQUARTERS HEADQUARTERS Registered Plans Directorate Income Tax Rulings Directorate Irina Schnitzer Attention: Jeff Boxer 2022-094270 Re: Royal Canadian Mounted Police (“RCMP”) Cadet Training – Eligible Service We are writing in response to your email dated July 5, 2022, wherein you requested our views on whether the period of cadet training completed by an RCMP cadet constitutes eligible service for purposes of subparagraph 8503(3)(a)(i) of the Income Tax Regulations (the “Regulations”). ... (footnote 1) In addition, in Dhillon v The Queen, 2002 DTC 2083 (“ Dhillon ”) the Tax Court of Canada concluded that in the circumstances presented at trial there was an employee/employer relationship between the RCMP cadet and the RCMP during the period of cadet training. ...

12 October 1993 External T.I. 9320490- Déductibilité des intérets — Interest Deductibility Unedited CRA Tags 20(1)(c) TABLE RONDE SUR LA FISCALITÉ FÉDÉRALE APFF — CONGRES 1993 Question 7 Dans le cadre du libre échange, Canco a incorporé une nouvelle filiale en propriété exclusive aux Etats-Unis("USCO") pour y étendre ses opérations. ...

23 November 1993 External T.I. 9322405 F- SR & ED Unedited CRA Tags 37(1)(a)(ii) XXXXXXXXXX  Attention:  XXXXXXXXXX Dear Sirs: RE:  Scientific Research & Experimental Development (SR&ED) This is in reply to your letter of July 30, 1993 wherein you requested further clarification that a fee arrangement charged by a non-resident company to a Canadian taxpayer for the right to manufacture or produce a product developed as a result of the SR&ED performed in Canada would not jeopardize the eligibility of the SR&ED expenditures for investment tax credits (ITC). ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4 CRA Tags Treaties Article XXIV 126(7) "non-business-income tax" 20(11) Treaties Article V Principal Issues: What credits and deductions are available to U.S. citizens resident in Canada on taxes paid in respect of dividend income now that rates have increased in conjunction with the "fiscal cliff". ... Reasons: Text of the treaty. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 4. ...

10 June 2013 Roundtable, 2013-0480411C6- STEP Roundtable – June 2013- Question 10 Principal Issues: Deductibility of probate and related fees by an estate. Position: Question of fact Reasons: In our view, the Tax Court of Canada's decision under the informal procedure was based on the unique facts of the case. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 10. ...

31 December 2015 External T.I. 2014-0556881E5- Bill C-43 – Calendar year for testamentary trusts CRA Tags 248(1) Principal Issues: Change in tax treatment of testamentary trusts arising from Bill C-43 may result in a deemed tax year end of December 31, 2015. ... King December 31, 2015 Dear XXXXXXXXXX: Re: Bill C-43 – Calendar year for testamentary trusts This is in reply to your email correspondence and our telephone conversations during which you asked if there is any transitional relief with respect to the legislative changes in Bill C-43 which require an existing testamentary trust, which will not be a graduated rate estate, to have a taxation year that coincides with the calendar year; commencing with a deemed taxation year of December 31, 2015. ...

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution CRA Tags 93(2) 93(2.01) Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to shares owned by a taxpayer in respect of which the taxpayer made a capital contribution consisting of shares of another foreign affiliate? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 7 – Subsection 93(2.01) substituted property rule and capital contributions Assume the following hypothetical facts: a) Canco owns all of the shares of each of FA1 and FA2. b) Canco capitalizes FA1 with $1,000 of equity. c) FA1 loans $1,000 to FA2 for use in its active business. d) A few years later, after having paid dividends of $50 to Canco, FA1 becomes a wholly-owned subsidiary of FA2 as a result of a contribution of capital by Canco of the shares of FA1 to FA2. ...