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.-- summary under Paragraph 149.1(4)(a) Summary Under Tax Topics- Income Tax Act- Section 149.1- Subsection 149.1(4)- Paragraph 149.1(4)(a) foundation’s registration subject to revocation because it had invested in a Delaware partnership (with stated separate existence) carrying on business A Quebec private foundation, which had invested in a foreign partnership (FP) that was governed by the Delaware Revised Uniform Partnership Act (DRUPA), submitted that “the FP is a separate legal entity from its members under the statutory provisions of the … DRUPA … by virtue of which it was created and consequently it is the FP that operates the business and not the members,” so that its registration was not subject to revocation under s. 149.1(4)(a). ...

18 December 2006 Internal T.I. 2006-0208611I7 F- Indemnités pour lésions professionnelles-- summary under Subsection 232(4) Summary Under Tax Topics- Income Tax Regulations- Regulation 232- Subsection 232(4) Reg. 232(4) exclusions are broader than those listed After indicating that the s. 56(1)(v) inclusion and s. 110(1)(f)(ii) deduction could apply to amounts paid by a bank pursuant to the Canada Labour Code to Ontario employees in amounts not in excess of the amounts that would have been payable pursuant to Ontario's Workplace Safety and Insurance Act scales, the Directorate stated: Pursuant to [Reg.] 232(1) …, every person who pays an amount in respect of compensation described in subparagraph 110(1)(f)(ii) of the Act shall make an information return in prescribed form in respect of that payment. That prescribed form is the T5007 slip …. Also excluded from the T5007 are amounts coming within subsection 232(4) of the ITR, such as interest payments, compensation for non-financial loss, payments under a labour market reintegration program, medical expenses and lump-sum payments to survivors. ...

The Directorate went on to state: The surplus of CFA could conceivably be adjusted where CFA’s “earnings” are computed pursuant to subparagraph (a)(i) or (a)(ii) of the definition of “earnings” under [Reg.] 5907(1) … and the relevant foreign tax law makes its own transfer pricing adjustment, whether by way of a corresponding adjustment or otherwise. …[C]onsideration would have to be given to whether subsection 5907(2) … could reverse that foreign tax law adjustment.... ...

24 October 2017 Internal T.I. 2017-0719531I7- Section 22 election and carrying on a business-- summary under Paragraph 87(2)(g) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(g) failure of s. 87()2)(g) to deem continuity for s. 22 purposes not fatal Immediately after its formation, Amalco dropped the business of a predecessor down to a partnership under s. 97(2) – except that it used the s. 22 election for the transferred trade receivables. The Directorate found that as a technical matter the s. 22 election was not available – effectively because s. 87(2)(g), which deemed Amalco to be a continuation of the predecessor for purposes of the ss. 20(1)(l) and (p) reserve provisions, did not go further to deem the Amalco receivables to have been includible in its income. ...

Since the premium at issuance is used to adjust the overall yield to reflect the prevailing market rate for similar securities at that time … this fact is an explicit indication that the interest rate on the loan exceeds a reasonable amount as required by virtue of paragraph 20(1)(c) …. ...

. … In this regard, section 122.3 does not contain any indication or restriction as to the contracting party to such a contract. Consequently, the fact that the contract is concluded with a person related to the specified employer does not have the effect of disqualifying the latter's employees from the OETC …. ...

Regarding the resulting disposition, the Directorate stated: [Here] there was a disposition of the seized equipment … at the time the court confiscated the property pursuant to section 16 of the Controlled Drugs and Substances Act. … [T]ax treatment of such equipment dispositions should be in accordance with the Act regardless of whether they are derived from illegal activity. ...

6 January 2005 Internal T.I. 2004-0100241I7 F- Imposition des rentes au décès-- summary under Paragraph 148(2)(b) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(2)- Paragraph 148(2)(b) no disposition of PAC under s. 148(2)(b) – but disposition if estate elects to commute Regarding the taxation of prescribed and non-prescribed annuity contracts on the death of the holder and annuitant (the "Annuitant"), the Directorate referred to ss. 148(2)(b) and (c), and then stated: [O]n the death of a prescribed annuity contract holder, the deemed disposition rule in paragraph 148(2)(b) does not apply. … If the annuity contract provides that on the death of the Annuitant, the Estate continues to receive the annuity amounts but also has the option to terminate the annuity contract and receive a lump sum, there will be a disposition of the prescribed annuity contract by the Estate when it makes the election. ...

. … It is … not required that the services be rendered to the payer, either the directors of the corporation (the employer) or the administrator of the settlement fund. ...

Before concluding that this annual amount also qualified as a support amount, the Directorate stated: … Robert Monette v. ... The Queen (T.C.C.) 94 DTC 1356 … concluded that the amount paid to reimburse the income tax on the taxable support received was related to the monthly support payments and represented a periodic allowance deductible pursuant to paragraph 60(b) and taxable pursuant to paragraph 56(1)(b). ...