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4 December 2013 Internal T.I. 2013-0489051I7- Personal-Use-Property & Article XIII(9)-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 personal-use land and building are one property A U.S. resident owned vacant land in Canada from before September 26, 1980 and after that date built a cottage thereon. ...

7 August 2015 Internal T.I. 2015-0585011I7- Osteopaths & naturopaths in Quebec-- summary under Subsection 118.4(2) Summary Under Tax Topics- Income Tax Act- Section 118.4- Subsection 118.4(2) Quebec osteopaths and naturopaths excluded in contrast to their eligibility for Quebec purposes Are osteopaths and naturopaths are authorized medical practitioners in the province of Quebec for purposes of the federal medical expense tax credit (METC)? ...

22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution-- summary under Clause 95(2)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) inter-affiliate loan generating deemed active business funded out of an interest-free loan from Canco A wholly-owned foreign affiliate (“Luxco1”) of Canco held 1/3 of the shares of a corporation ("NRco"), which was resident in a Treaty country and carried on an active business there. ...

2 May 2005 Internal T.I. 2005-0119971I7 F- CDA- Excessive Election & Late Filed Election-- summary under Subsection 184(3) Summary Under Tax Topics- Income Tax Act- Section 184- Subsection 184(3) where the corporation failed to file s. 83(2) election, CRA should assess Pt. ...

5 April 2018 Internal T.I. 2017-0728581I7- Ss 125(3.2) & 125(8) amending the business limit-- summary under Paragraph 125(3.2)(d) Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(3.2)- Paragraph 125(3.2)(d) business limit allocation may be amended within statute-barring period In essentially confirming 2009-0351721E5 to the effect 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, CRA stated: [P]aragraph 125(3.2)(d) provides that both CCPCs must file a prescribed form with the Minister in their return of income for their respective taxation years for the assignment to be valid. ...

7 May 1995 Internal T.I. 9510220- PART I.3, O/S CHEQUES & OVERDRAFTS-- summary under Subsection 181.2(3) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3) Bank overdrafts are considered to have arisen to the extent that they have been utilized or drawn upon. ...

30 July 2003 Internal T.I. 2003-0024037- ACB OF LAND & BUILDING-- summary under Paragraph 20(1)(cc) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(cc) ss. 20(1)(cc), (dd) and (ee) deductions for amounts otherwise on capital account Respecting the determination of ACB of where a medical doctor acquired land and constructed a building that is used to earn business income, CRA stated: [G]enerally all of the outlays and expenses incurred in respect of the acquisition of the land and construction of the building will be considered incurred on account of capital, and consequently, will constitute part of the ACB of the particular properties. ...

8 December 2003 Internal T.I. 2003-0042537 F- CIEE & SRAS-- summary under Subsection 122.3(1) Summary Under Tax Topics- Income Tax Act- Section 122.3- Subsection 122.3(1) lay-off due to SARS did not qualify as an absence After taking leave in Canada in accordance with the terms of their employment regarding an offshore project, the employees’ return to the project was refused by the local authorities due to the intervening outbreak of the SARS epidemic, so that they were laid off for some time. ...

8 October 2004 Internal T.I. 2004-0093371I7 F- Crédit d'impôt à l'investissement & impôt minimum-- summary under Subparagraph 127(5)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(5)- Paragraph 127(5)(a)- Subparagraph 127(5)(a)(ii) carryback of ITCs from year where the taxpayer was subject to minimum tax After noting that where minimum tax applies in a particular taxation year (here, 2003), the deductible amount of investment tax credit in respect of property acquired in that year is limited under s. 127(5)(b) to the amount by which the tax otherwise payable under Part I for the year (2003) exceeds the minimum tax applicable to the individual for that year, the Directorate went on to note that the unused investment tax credit balance be carried back to previous years (2000 to 2002) if the investment tax credit amount is higher than this excess: for purposes of the carryback to such prior years, s. 127(5)(a)(ii) takes into account the balance that was not deductible in the particular taxation year (2003). ...

& Section 116116(5)-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...