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Technical Interpretation - Internal summary
27 September 2016 Internal T.I. 2015-0572901I7 - Deferral of employment benefit under ss. 7(8) -- summary under Paragraph 73(1.01)(b)
. … [W]here capital property is transferred by Taxpayer A to Taxpayer B in settlement of rights arising out of their marriage or common-law partnership (see paragraph 73(1.01)(b) and subsection 73(1)), Taxpayer A will be deemed to have disposed of the shares for proceeds equal to Taxpayer A’s adjusted cost base (ACB) of the shares immediately before the disposition. ...
Technical Interpretation - Internal summary
15 November 2016 Internal T.I. 2016-0656351I7 - Corporate Minimum Tax Eligible Loss Calculation -- summary under Subsection 58(2)
. … In conclusion, a corporation that becomes subject to CMT will be required to determine its eligible losses for a particular taxation year as if it had been subject to CMT in previous taxation years. ...
Technical Interpretation - External summary
13 February 2017 External T.I. 2015-0570011E5 - Compensation by non-resident-loss of rental income -- summary under Paragraph 212(1)(d)
. … When an amount is paid to a taxpayer in a year to compensate for the loss of rental income, [CRA] would generally consider the compensation to be rental income for that year. ...
Technical Interpretation - External summary
20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules -- summary under Subsection 90(9)
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Technical Interpretation - Internal summary
11 September 2015 Internal T.I. 2015-0586301I7 - Premiums received on re-opening of debt -- summary under Variable E
. … [T]he premiums received by the Taxpayer could now fall within amended variable E of the definition of CEC, assuming that the amounts…have [not] reduced the amount of an outlay or expense, (i.e., …if a reduction to paragraph 20(1)(c) did not apply as discussed above.) ...
Technical Interpretation - External summary
14 March 2017 External T.I. 2016-0627311E5 F - Deduction of contribution to an IPP or RCA -- summary under Salary Deferral Arrangement
. … In general, supplementary pension benefits are considered to be reasonable when the terms of the supplemental pension plan are substantially the same as those of the IPP. ...
Technical Interpretation - External summary
14 March 2017 External T.I. 2016-0656101E5 F - Death Benefit -- summary under Death Benefit
. … After indicating that when the amount was recorded in the minutes did not affect its character, CRA stated that “the payment of the death benefit may be staggered over more than one taxation year.” ...
Technical Interpretation - External summary
31 March 2017 External T.I. 2016-0630351E5 - Return of a gift -- summary under Subsection 118.1(26)
. … Where the original property is returned, the taxpayer is deemed not to have disposed of the property nor to have made a gift. ...
Technical Interpretation - External summary
31 March 2017 External T.I. 2016-0630351E5 - Return of a gift -- summary under Charitable Foundation
. … [T]he determination of whether the gift of the life insurance policy to the foundation was subject to a condition subsequent or whether the foundation can legally return the life insurance policy is a question of law and beyond the scope of this technical interpretation. ...
Conference summary
26 April 2017 IFA Roundtable Q. 5, 2017-0691121C6 - Foreign tax credit Brazilian interest on equity -- summary under Subsection 91(4.7)
If the Brazilian affiliate had a chain of other foreign affiliates under it, that could also by reason of the chain rules result in the denial of FAT in respect of FAPI for those underlying subsidiaries – or for subsidiaries up above, as well. ...