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21 September 2007 External T.I. 2007-0229191E5 F- Agent de voyages & impôt de la partie I.3-- summary under Subparagraph 181(3)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3)- Paragraph 181(3)(b)- Subparagraph 181(3)(b)(i) customer advances received by travel agents and reported as deferred revenue in their balance sheets were required to be included in taxable capital even though amounts held in trust Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them in a trust account, and also, in their year end balance sheets, reported the current balances in the trust accounts as assets and also as liabilities, labelled as "customer deposits and deferred revenue". ...

21 September 2007 External T.I. 2007-0229191E5 F- Agent de voyages & impôt de la partie I.3-- summary under Paragraph 181.2(3)(c) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3)- Paragraph 181.2(3)(c) customer advances received by travel agents and reported as deferred revenue in their balance sheets were “advances” Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them in a trust account, and also, in their year end balance sheets, reported the current balances in the trust accounts as assets and also as deferred-revenue liabilities. ...

21 January 2008 External T.I. 2007-0227531E5 F- GRIP / GRIP Addition for 2006-- summary under Subsection 89(14) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(14) for 2006 only, CRA accepted designating a portion of a dividend as an eligible dividend Where, in 2006, Bco's GRIP is $1.3 M and, pursuant to s. 84(3), Bco is deemed to have paid a dividend of approximately $1M to Cco and Dco (approximately $500,000 each), can Bco designate a fraction of the deemed dividend representing Bco's safe income on hand attributable to the purchased shares (approximately $700,000) as an eligible dividend, pursuant to s. 89(14)? ...

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. ...

4 May 2005 External T.I. 2005-0120271E5 F- Change of Control- CDA & RDTOH-- summary under Clause 256(7)(a)(i)(A) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(7)- Paragraph 256(7)(a)- Subparagraph 256(7)(a)(i)- Clause 256(7)(a)(i)(A) s. 256(7)(a)(i)(A) applied where taxpayer acquired shares of CCPC from his sister Ms. ...

6 October 2017 APFF Roundtable Q. 1, 2017-0708971C6 F- Inactive Corporations & subs. 162(7) ITA-- summary under Paragraph 150(1)(a) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1)- Paragraph 150(1)(a) requirement for Canco to file nil T2 returns, but no penalty What was the CRA position on: (a) the obligation of an inactive Canadian corporation to file a T2 return for each of the years in which there is no business activity and, thus, no tax payable; and (b) the application of late-filing penalties? ...

6 July 2018 External T.I. 2018-0759521E5- Tax on split income & preferred beneficiary-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (c) income to preferred beneficiary is not split income A trust that is a limited partner of a partnership (“LP”) providing back office support to a general partnership of accounting professionals (“Partnership”) as its only source of income has a minor disabled beneficiary who qualifies as a “preferred beneficiary.” ...

6 July 2018 External T.I. 2018-0759521E5- Tax on split income & preferred beneficiary-- summary under Subsection 104(14) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(14) split income rules do not apply to preferred beneficiary income The definition of split income includes trust income distributions under s. 104(13) but not preferred beneficiary amounts under s. 104(14). ...

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. ...

1 September 1994 External T.I. 9413775- ELIGIBLE PROPERTY & CUM DIVIDENDS-- summary under Subsection 85(1.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1) right to accrued but undeclared dividends was not a separate eligible property from the preferred shares Before indicating that a preferred share with accrued cumulative dividends could be transferred by an individual to a holding corporation under s. 85(1) or exchanged for other shares of the corporation pursuant to a reorganization of capital described in s. 86(1) without the accrued dividends being recognized as income, Revenue Canada rejected the position that such accrued dividends would be an eligible property separate form the shares themselves, stating: The right to accrued cumulative dividends would be just one of the bundle of rights that would be attached to a particular share.... ...