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These are additions to our set of 2,521 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ¼ years of releases of such items by the Directorate. ...

Similar consequences would attend the redemption of loyalty points by a customer in exchange for a free service provided by Bco or the dealer – except that, regarding Aco’s payment to Bco respecting the points redeemed by Bco, no ITC would be generated to Aco: s. 181(5)(c) would not be met, i.e., the coupon does not entitle the recipient of the supply by Bco or the dealer to a reduction of the price of the taxable supply by a fixed dollar amount specified in the coupon, and instead the recipient of the service, on redeeming the points, opts in lieu of a fixed dollar amount off the price of widgets for a free service, the value of which varies depending on the location where the service is performed. ...

These are additions to our set of 2,565 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,571 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,584 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,597 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2023-10-11 24 January 2023 External T.I. 2018-0753471E5 F- Supplément remboursable pour frais médicaux Income Tax Act- Section 122.6- Adjusted Income adjusted income does not include income of spouse who died in the year 9 June 2017 External T.I. 2017-0700961E5 F- Retenues à la source Income Tax Regulations- Regulation 100- Subsection 100(3)- Paragraph 100(3)(c) no withholding where RCA pays retiring allowance to RRSP that is an s. 60(j.1) eligible amount or within the RRSP deduction limit 2002-10-25 5 November 2002 External T.I. 2002-0160815 F- CDC HYPOTHEQUE Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (d) change in policy re CDA credit for life insurance proceeds paid to creditor is retroactive re the computation 7 November 2002 External T.I. 2002-0168795 F- REER TRANSFERT D'ACTIONS AU RENTIER Income Tax Act- Section 146- Subsection 146(8) shares can be distributed out of RRSP to annuitant – but with their FMV being included as a benefit 14 November 2002 Internal T.I. 2002-0171377 F- REER PLACEMENT ADMISSIBLE Income Tax Act- Section 204- Qualified Investment- Paragraph (a) money means currency 14 November 2002 External T.I. 2002-0136485 F- REVENU D'ENTREPRISE ET REVENU DE BIEN Income Tax Act- Section 129- Subsection 129(4)- Income or Loss long-term rental of excess space unlikely to be assimilated to business income 21 November 2002 External T.I. 2002-0141455 F- TITRES DETENUS PAR UN FIDUCIAIRE Income Tax Act- 101-110- Section 108- Subsection 108(1)- Trust- Paragraph (a.1) exclusion of s. 7(2) trusts for greater certainty 30 October 2002 Internal T.I. 2002-0146787 F- PRET SANS INTERET A UNE FILIALE Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest incurred to make interest-free loans to non-resident subsidiary was deductible if an expectation of income from its shares ...

& Disc. Div. Shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) payment of dividends on discretionary dividend shares with no liquidation entitlement would not result in a significant reduction 30 October 2002 External T.I. 2002-0126045 F- TRANSFERT A UN MINEUR Income Tax Act- Section 248- Subsection 248(1)- Specified Member contributions of the specified member to the partnership business must be instrumental to its success ...

In summarized form, the list now consists of: A taxpayer buys an interest in a partnership which, immediately prior thereto, had realized the gain legs on straddle transactions in FX forward contracts (with such gain allocated to the selling partner) – and with the loss legs then being realized and allocated to the taxpayer. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-09-13 4 October 2002 Internal T.I. 2002-0139807 F- REMBOURSEMENT DE TPS Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- J GST rebate received after sale of asset would not, under J of UCC formula, produce recapture Income Tax Act- Section 13- Subsection 13(7.1) GST rebate claim reduced UCC pursuant to J of formula rather than under s. 13(7.1, since claimed after asset’s disposition Income Tax Act- Section 6- Subsection 6(8)- Paragraph 6(8)(b) GST rebate claimed by employee re CCA on car after its sale reduces UCC pursuant to J of formula rather than under s. 13(7.1) 4 October 2002 Internal T.I. 2001-010564A F- PENSION ALIMENTAIRE-ARRERAGES Income Tax Act- Section 60- Paragraph 60(b) lump sum payment in settlement of periodic support payments in arrears is an amount payable on a periodic basis General Concepts- Payment & Receipt set-off does not constitute payment unless the parties so agree 2 October 2002 External T.I. 2002-0118815 F- DIABETE JUVENILE Income Tax Act- Section 118.3- Subsection 118.3(1)- Paragraph 118.3(1)(a.1) child with juvenile diabetes does not generate the infirm credit, including under para. ...