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3 July 2019 Internal T.I. 2019-0791521I7- Tuition tax credit- University outside Canada-- summary under Subparagraph 118.5(1)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 118.5- Subsection 118.5(1)- Paragraph 118.5(1)(b)- Subparagraph 118.5(1)(b)(i) CRA will follow Fortnum in “factually similar” situations In response to a request as to its interpretation of s. 118.5(1)(b) following Fortnum, CRA first noted that, regarding the attendance of the taxpayer in that case at a 10- week summer semester consisting of 11 courses each of one or two weeks’ duration, “the court applied the three consecutive week requirement to the summer semester as a whole, rather than to each individual course in the semester,” and then stated: Our interpretation of subparagraph 118.5(1)(b)(i) … as explained in paragraph 2.10 of … S1-F2-C2.. has generally not changed as a result of … Fortnum. … [T]his case was heard … under the Informal Procedure … [and] do[es] not have precedential value. ...

Our position is supported by … Berkovic … 83 DTC 335 and …. Mitosinka …. ...

17 April 2003 Internal T.I. 2003-0181507 F- PRET SANS INTERET-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) accessing the exceptional circumstances test requires demonstrating “a sufficient connection between the interest-free loan and an indirect source of the person's income” After surveying the jurisprudence on the exceptional circumstances test, the Directorate stated: Interest deductibility in other situations involving interest-free loans by a person to a corporation of which the person is not a shareholder may be justified on the particular facts of the case, as in Canadian Helicopters … and … Byram … to the extent that the person can show that there is a sufficient connection between the interest-free loan and an indirect source of the person's income. ...

. … Furthermore … the favourable tax results … are similar … to those available under the employee stock option rules …. even though … the requirements of paragraph 110(d) or (d.1) are not satisfied. ...

. … Finally … Ahmad … held that pre-judgment interest was not taxable because no amount was owed to the taxpayer before the judgment was rendered. ...

The Directorate stated: [B]ased on the terms of the Payment Agreements … Canco agrees to make advanced payments to NR that are set off or deducted from the amount due by Canco to NR required under the Initial Contract. ... As such, the nature of the payments is different from [those] … in … 2008-29716 …. ... Accordingly … the advance payments made by Canco to NR under the Payment Agreements are subject to the withholding requirements of section 105 …. ...

Repairs or Running Expense expenditure on Canadian film production can be current expense if it is only of short-term use Is whether an expenditure on a "Canadian film or video production” ("CFVP") is a current expense, or a capital expenditure on depreciable property, determined in accordance with the criteria set out in 9722707, which states: Generally, the cost of preparing a tape will normally be considered a current expenditure where the tape is only of short-term use, either because it is merely of current topical interest or because it is intended to be shown only once (…) In these latter situations, the material is normally retained on the tape for record purposes only. ... CRA responded: The criteria set out in that paragraph may still be used …. … In addition … a likelihood of a particular production generating revenues other than those provided for in the original broadcast contract, for example, from the sale of DVDs, the awarding of contracts for broadcasting on the Internet, on specialty channels or in territories not covered by the original broadcast contract, can also be taken into consideration in determining whether the costs related to a production should be considered as capital expenditures in respect of depreciable property. … [W]here the broadcast contract covers a period of several years, under which the broadcaster has the right to broadcast the production several times during that period, this would be an argument to support that the costs associated with the production provide a lasting benefit to the producer. ...

" While IT-283R2 has been archived … the above statement … is still valid. … In regard to the CCA class, paragraph 8 of IT-472 [states]: " … The Department considers the following property to be so included in Class 8:... ...

For the latter amount to be accepted, it must be reasonable in amount, as to which the Directorate stated: Although the maximum amount provided for in paragraph 53(2)(e) … is $20,000, it is possible that, in similar cases, the Tribunal may award only a relatively small amount compared to this maximum. …[W]e have … asked … for information concerning … human rights at the provincial level. We found that … human rights tribunals in several provinces (some of which had a maximum limit for general damages of less than $20,000 and some of which had no maximum limit at all) generally only awarded amounts below the maximum limit for general damages. ...

The Directorate stated: # 2007-022925 and # 2004-0107761E5 … stat[ed] that in situations similar to those of Ms. ...