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19 March 2001 External T.I. 2001-0063345 F- RS & DE- MANDATAIRE-- summary under Clause 37(1)(a)(ii)(E) Summary Under Tax Topics- Income Tax Act- Section 37- Subsection 37(1)- Paragraph 37(1)(a)- Subparagraph 37(1)(a)(ii)- Clause 37(1)(a)(ii)(E) organization did not qualify under s. 37(1)(a)(ii)(E) because it made disbursements only as agent The applicant did not qualify under s. 37(1)(a)(ii)(E) because it disbursed amounts to other entities only as agent for taxpayers and thus did not “carry on activities that consist of receiving amounts from taxpayers, other than as an agent of the taxpayers, and redistributing those amounts to the associations, institutions or corporations referred to in clauses 37(1)(a)(ii)(A) to (C).” ...

1999 Ruling 9903543- TOTAL RETURN SWAPS & MUTUAL FUND TRUST-- summary under Timing Summary Under Tax Topics- Income Tax Act- Section 9- Timing An open-end unit trust invests the proceeds of a public offering in a note of a bank and then enters into a total-return swap with the Bank respecting a bond index (some of the components of which correspond to bonds held by the bank). ...

15 January 2021 External T.I. 2020-0847781E5- CEWS- remuneration / SSUC- rémunération-- summary under Eligible Remuneration Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Eligible Remuneration non-cash taxable benefits are not “eligible remuneration” An “eligible employee” of an eligible entity excludes an individual who is without remuneration by the eligible entity in respect of 14 or more consecutive days in a qualifying period ending before July 5, 2020. ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 4, 2020-0851621C6 F- RRSP or RRIF on death – Joint election-- summary under Subsection 146(8.1) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8.1) a specific bequest of a RRSP proceeds to a surviving spouse cannot be treated as a refund of premiums (a) Where an unmatured RRSP is the subject of a particular legacy to the deceased annuitant's spouse and the RRSP proceeds are distributed by the RRSP issuer directly to the surviving spouse, does the CRA require Form T2019 to be filed? ... Since the executor exercises the seisin of the legatee by particular title at the formation of the estate, in such a case, the amount paid under the deceased annuitant's RRSP is part of the annuitant’s estate, with the result that such an amount would not qualify as a "refund of premiums" within the meaning of subsection 146(1), even though the proceeds of the RRSP are paid by the issuer of the RRSP directly to the surviving spouse in accordance with the instructions of the executor. … Thus, as specified in subsection 146(8.1), the executor and the Spouse will have to file Form T2019 jointly if they wish to designate the amounts that the estate received (or, as the case may be, is considered to have received) from the deceased annuitant's RRSP as a refund of premiums received by the Spouse. ...

10 October 2024 APFF Roundtable Q. 11, 2024-1028921C6 F- Récupération d’amortissement liée à un bien de la catégorie 10.1 – travailleur autonome-- summary under Paragraph 13(7)(d) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(d) where a vehicle is used both personally and for business by a self-employed worker, there is a choice between a simplified method, and that under ss. 13(7)(c) and (d) CRA considers that the CCA deduction for the motor vehicle of a self-employed worker that is used for both business and personal use can be computed by determining the amount of CCA in respect of the motor vehicle as if it were used entirely for business purposes, while deducting annually only the proportion of CCA corresponding to the business use in the particular year. ... Since the cost to him of the passenger vehicle (a designated immediate expensing property per Reg. 1104(3.1)) was higher than the Reg. 7307(1) limit, s. 13(7)(i) provided that the proceeds of disposition were computed as: $38,000 X $34,000/ $50,000 = $25,840, resulting in recapture of depreciation. ...

8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6- Qualifying person & multiple shares-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A The correspondent noted that in Canada, if each class of shares of a public company with multiple classes must be considered separately for purposes of satisfying the de minimis or 10-percent tests in the U.S. tax regulations (treated as being applicable for Canadian purposes under para. 2(c) of the "qualifying person definition) very few Canadian corporations with multiple classes of voting shares will be considered "qualifying persons" for purposes of the LOB clause. ...

5 September 2002 External T.I. 2002-0147315- PARTNERSHIP AS A PARTNER & 98 (3)-- summary under Subsection 98(3) Summary Under Tax Topics- Income Tax Act- Section 98- Subsection 98(3) lower-tier partnership wind-up Can s. 98(3) be used where one (or all) of the partners in the particular partnership are themselves partnerships? ...

24 March 2005 Internal T.I. 2005-0115921I7- Specified debt obligations & loan originating cost-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract debt definition- includes conditional sales contracts Conditional sales contracts purchased by a corporation likely would qualify as "debt obligations," so that the corporation would qualify as a restricted financial institution, i.e., a corporation whose principal business was the purchasing of debt obligations issued by arm's length persons. ...

11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit-- summary under Subsection 126(2) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(2) The Directorate agreed that the taxpayer, which was a Canadian maunufacturer transferring some of its goods to a Japanese branch for sale there, was overstating its profits for purposes of s. 126(2), by treating most or all of the profits on the sale of such products as being profits of the Japanese branch. ...

2012 Ruling 2011-0429961R3- Hydrocarbon & Immovable property: Canada-UK Treaty-- summary under Subsection 116(6.1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(6.1) Ruling that the transfer of shares of a UK company (Forco2) by two other UK companies (Forco1 and Forco4) would be exempt under Art. ...