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15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares-- summary under Subsection 84(3) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(3) MacMillan Bloedel to be followed Confirmation of a previous position that in light of the MacMillan Bloedel decision, CRA intends to assess any redemption of foreign-currency-denominated redeemable and retractable preferred shares on the basis that s. 39(2) applies to the issuer corporation. ...

14 July 1994 Internal T.I. 9407377- NON-RESIDENT PARTNER & 216 ELECTION (7558-3)-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) Brief discussion of application of s. 216 election where there is a non-resident partner in a partnership receiving rents from a MURB property. ...

8 September 1994 Internal T.I. 9420937- HUSBAND & WIFE PARTNERSHIP-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Before discussing the case law in the context of a dispute, RC stated that "in general, an acceptable partnership requires an investment by each partner, a written partnership agreement and proper notices to creditors and financial institutions concerning the existence of a partnership". ...

10 February 1994 Internal T.I. 9316307 F- Indians — Taxation of Income from Various Sources-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) Discussion of the four tests that are applied by the courts in distinguishing between a contract of service and a contract for services. ...

10 May 2001 Internal T.I. 2001-0065827 F- FINES + PENALTIES- INTÉRETS ET PÉNALITÉS-- summary under Paragraph 18(1)(t) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(t) s. 18(1)(t) enacted for greater certainty CRA noted that Ioegen (96 DTC 1993) found that s. 18(1)(t) was enacted for greater certainty. ...

14 March 2013 Internal T.I. 2012-0451131I7- Trustee's Rights & Obligations under the Act-- summary under Paragraph 241(4)(k) Summary Under Tax Topics- Income Tax Act- Section 241- Subsection 241(4)- Paragraph 241(4)(k) The Minister may disclose information respecting the bankrupt to the trustee in bankruptcy without a T103 given that the trustee is deemed to be the bankrupt's agent by s. 128, and the trusteee is entitled to taxpayer information under s. 164(1) of the Bankruptcy and Insolvency Act. ...

8 November 1996 Internal T.I. 9635527- INTERACTION SECTION 216 & SECTION 188.94-- summary under Section 118.94 Summary Under Tax Topics- Income Tax Act- Section 118.94 Even though Part XIII tax is levied on the gross amount of a particular payment, for the purpose of calculating a non-resident's world income such amount is reduced by applicable expenses. ...

8 November 1996 Internal T.I. 9635527- INTERACTION SECTION 216 & SECTION 188.94-- summary under Subsection 216(1) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(1) "The filing of a return of income pursuant to section 216 cannot have any impact on whether or not an individual meets the 'all or substantially all' test in section 118.94. ...

28 April 1994 Internal T.I. 9331017- TERMINAL LOSSES & LOSS OF TAX EXEMPT STATUS-- summary under Subsection 149(10) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(10) A terminal loss in the year of change from exempt to taxable status is deductible. ...

30 September 1994 Internal T.I. 9414527- BORROWINGS & EXCESS INSURANCE COLLATERAL-- summary under Paragraph 20(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.2) Where the life insurance coverage under an assigned policy is $500,000 and the average balance owing under the borrowing is $200,000, the amount deductible under s. 20(1)(e.2) is limited to 40% of the lesser of the premiums payable and the net cost of pure insurance under the policy for the year. ...