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15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) s. 39(2) application on USD pref redemption, cf. if USD common shares The redemption of U.S. ... However, the Directorate noted its previous comments that MacMillan Bloedel “ deals with the redemption of redeemable and retractable preferred shares, which may be viewed as similar to the repayment of a debt obligation” and it is “not prepared to extend the reasoning to a redemption of shares in general.” ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(4) to be improvements or alterations to leasehold interest, property acquisitions must be assimilated to landlord’s property The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ... Regarding whether the costs of such work should be added to the cost of the taxpayer’s Class 13 leasehold interest pursuant to Reg. 1102(4) before regard was had to Reg. 1102(5), CRA stated: [A]n amount expended is for the making of improvements or alterations to a leased property within the meaning of subsection 1102(4) where such expended amount relates to property that is incorporated into the leased property and becomes the property of the lessor. … Generally, the owner of a building owns everything that is joined to the building. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership leasehold improvements are assimilated to the landlord’s property unless the lease specifies otherwise Before quoting from Mount Robson in this regard, the Directorate indicated that: Generally, the owner of a building owns everything that is joined to the building. ...

13 June 2012 Internal T.I. 2012-0435351I7 F- SEPE- chèques en circulation-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in Quebec, payment by cheque does not occur until debiting of bank account Are the cash assets of Opco reduced by the amount of issued and outstanding cheques that have not yet been cashed? CRA responded: Under the civil law in force in Quebec, the delivery of an outstanding cheque does not constitute payment … [and] the date of payment of a debt settled by cheque is considered to be the date on which the cheque is honoured or paid by the bank …. [Here] the cheques in circulation and not yet cashed do not constitute payments of the amounts due to Opco's suppliers and … consequently, there can be no reduction in the amount of the cash of Opco as long as the bank does not honour or pay such cheques. ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Paragraph 95(3)(b) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(3)- Paragraph 95(3)(b) R&D services of CFAs not immediately related to the sale of goods by Canco Four U.S. ... After finding that s. 95(2)(b) applied to the R&D Services provided to Canco, the Directorate rejected Canco’s argument that the R&D Services provided to Canco should be considered to be services performed in connection with the sale of goods under s. 95(3)(b), stating: [T]he phrase “services performed in connection with the (...) sale of goods” is limited to services that are directly related to the sales function ….[T]he structure of the phrase refers to activities that are immediately linked or related to the process of selling goods and transferring ownership in the goods from the seller to the purchaser, requiring that the services be directly performed in the actual sale or negotiation process. … [T]he R&D Services … would generally not be immediately linked or related to the process of selling goods and transferring ownership in the goods from the seller to the purchaser. ...

5 April 2018 Internal T.I. 2017-0728581I7- Ss 125(3.2) & 125(8) amending the business limit-- summary under Paragraph 125(8)(c) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(8)- Paragraph 125(8)(c) partner assignment of its SPBL may be amended within the statute-barring period – and can be sliced and diced Does the CRA position (see 2009-0351721E5) that an associated group of Canadian-controlled private corporations can file amended T2 Schedule 23s provided that the amended allocation agreement does not change the amount allocated to any associated corporation for a taxation year for which a reassessment is statute-barred, apply respecting an amended assignment of a partner’s specified partnership business limit? CRA responded: [A] person’s SPBL for a taxation year is the person’s proportionate share of the partnership’s notional small business limit reduced by any amount that the person assigns to a “designated member” … under subsection 125(8). … In general terms, a person that is a member of a partnership can assign all or part of the person’s SPBL to a CCPC if the CCPC is a designated member of that partnership and meets the conditions specified by subsection 125(8). ...

25 September 2003 Internal T.I. 2003-0032837 F- Market Maker: Reserve Account for Losses-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt by employee where reserve loss account (funded out of commissions) is transferred from old brokerage employer to new brokerage employer A firm (ABC), that employed market makers, maintained a separate account for each employee into which a portion of the commissions earned by the employee was retained and held in a contingency loss reserve account, which was to be used to cover any losses resulting from the employee's transactions, and with the employee having access to the account on leaving the employment – except that where the employee moved employment to another member firm of the same clearinghouse ABC could, at the request of and for the benefit of the employee, transfer the funds accumulated in its reserve account to another similar account administered by the new employer. In finding that such transfer would be subject to withholding under s. 153(1)(a) on the basis inter alia that there was constructive receipt by the employee, the Directorate stated: [T]his payment is made to the employee by ABC, even if the employee does not receive it directly. … The employee chooses to direct the payment to the new employer's reserve account for the employee’s benefit, rather than personally collecting the funds. ...

15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date large FMV discrepancy suggested lack of bona fide valuation so that price adjustment clause need not be applied/ if applied, s. 85(1) election must be amended Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. ... The jurisprudence has shown that a price adjustment clause can be ignored in cases where there is no good faith effort to determine the FMV of a property (See: Guilder News ….). On this basis, it seems to us that you would be free to ignore the price adjustment clause and therefore maintain an assessment under 85(1)(e.2). … [If] you decide to recognize the price adjustment clause … the taxpayer must file an amended election to give effect to the price adjustment clause. ...

8 June 2018 Internal T.I. 2018-0744881I7- Regulation 403 – allocation of income-- summary under Subsection 403(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 403- Subsection 403(3) PE for 403(3) purposes includes any PE of any partnership of which insurer is member An insurance corporation (that reinsures policies issued by another insurer) holds partnership interests in several partnerships that have no insurance business and have permanent establishments in other provinces, but are not involved in an insurance business. ... Consequently … the taxpayer will have a PE in any province where the partnerships have a PE. … [B]ased on the fact that the taxpayer derives income (premiums) from reinsuring property situated in a province where the taxpayer has a PE due to being a member of a partnership, subsection 403(1) of the Regulations will allocate the taxpayer’s taxable income on a proportional basis to that province. … In view of the taxpayer having a PE in the province(s) where the partnerships have a PE, subsection 403(3) does not apply to the taxpayer with respect to those provinces. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under A Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A cost of installing property part of that property’s cost The taxpayer, which subleased premises on which were “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and electrical, ventilation and plumbing work and performed other work to make the premises suitable for use in its manufacturing and processing (“M&P”) work, and took the position that the portion of the costs should be included in the capital cost of equipment that was used directly or indirectly primarily for the M&P of goods for sale (the "M&P Properties"), namely, the cost of installing the M&P Properties (the "M&P Installation Costs") and as the cost of goods specifically required to perform such installation and to commission the M&P Property (the "M&P Commissioning Property) should be included in Class 29 rather than Class 13. In addressing whether such costs were costs of the M&P Property or costs of the M&P Commissioning Property, the Directorate stated: [T]he costs of installing equipment and bringing it into service generally include the costs of connecting it, for example to the building's electrical system, to the extent that these costs are identifiable and serve only that equipment. … If you determine that the portion of the M&P Installation Costs and the costs of the M&P Commissioning Property represents installation costs and expenses incurred to bring an M&P Property into service, the portion of those costs will therefore be included in the same Class as the M&P Property. … [I]f you determine instead that the portion of the M&P Installation Costs and the costs of the M&P Commissioning Property does not represent installation costs and expenses incurred to bring an M&P Property into service, the portion of those costs will not be included in the same Class as the M&P Property. Instead, the M&P Commissioning Property will be included in the Class appropriate to the M&P Commissioning Property itself, for example electrical wiring and plumbing pipes …. ...