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5 October 2012 Roundtable, 2012-0451261C6 F - Foreign entity classification -- summary under Corporation

After summarizing it two-step approach to entity classification, CRA stated: The CRA has not established a list of essential features that a foreign Entity must possess to be classified in any of the different categories of recognized Entities …. ...

2014 Ruling 2014-0530961R3 - Cross-Border Butterfly -- summary under Subparagraph 55(3.1)(b)(i)

See summary under s. 55(1) – distribution. ...

28 May 2015 IFA Roundtable Q. 7, 2015-0581611C6 - IFA 2015 Q7: Foreign affiliates-surplus adjustments -- summary under Subsection 5905(7.2)

On this basis, while the exempt surplus of FA3 would be reduced to $25, … Merged FA's opening exempt surplus is $200. ...

2 April 2014 External T.I. 2012-0473151E5 F - Limitation du coût de location d'un véhicule -- summary under Subsection 248(16)

Therefore … if sales taxes are included in the lease charges, the consumption tax amounts recovered in respect of the lease of the vehicle will be included in element E in the formulas under paragraphs 67.3(c) and (d) for the purpose of calculating the limitation in section 67.3. ...

11 July 2013 External T.I. 2013-0490591E5 F - Montant pour une personne à charge -- summary under Subsection 2(1)

…[T]he sole fact of the non-resident taxpayer being in a conjugal relationship with the Other Person would not make him a resident of Canada …. ...

7 May 2014 Internal T.I. 2012-0433731I7 - Application of subsections 92(5) and (6) -- summary under Subsection 92(5)

. … Canco was deemed to realize a gain in Year 3… equal [to] the total of amounts deducted by Canco under paragraph 113(1)(d) in respect of Forco dividends received through LP that were paid out of Forco's pre-acquisition surplus, less any foreign tax paid in respect of Canco's share of those dividends. ...

14 November 2013 Internal T.I. 2013-0485331I7 F - REÉR et revenu d'un Indien -- summary under Section 87

. … [I]n 2009-033576, there was no withdrawal from the RRSP. ...

6 May 2009 External T.I. 2008-0295581E5 F - Bourses et aide financière aux médecins -- summary under Paragraph 56(1)(n)

These sums must be reported on a T4A slip …. ...

5 July 2013 Internal T.I. 2013-0489821I7 F - Application of subsection 18(3.1) -- summary under Subsection 18(3.1)

And finally: … only the part of the property taxes attributable to the renovation period that are related to the ownership of the land subjacent to the building, as well as any land meeting the requirements of subparagraph 18(3.1)(a)(ii), should be added to the cost of the building. ...

19 July 2013 External T.I. 2012-0458961E5 F - Stock option, cashless exercise -- summary under Paragraph 7(1)(a)

After referring to Guide T4130, p. 24 and stating that the s. 7(1)(a) benefit is computed on the basis of the shares' fair market value "at the moment of their acquisition," CRA stated (TaxInterpretations translation): … [I]n the context of a short sale, the CRA is generally of the view that an employee has acquired the shares of the employer at the moment the employer transfers the shares to the employee and they are paid for. ...

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