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17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)-- summary under Paragraph 250(1)(a) Summary Under Tax Topics- Income Tax Act- Section 250- Subsection 250(1)- Paragraph 250(1)(a) "It is a question of fact whether a taxpayer, who is a resident of a foreign country and who is present in Canada for more 182 days in a year, sojourns in Canada for more than 182 days in that year. ...

17 February 1995 External T.I. 9400545- RESIDENCE & SOURCE DEDUCTIONS (HAA7576-1)-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 "Where a U.S. resident who is not a factual or deemed resident of Canada exercises his employment in Canada, his employer... is required to withhold source deductions in respect of the employment under subsection 153(1) of the Act even if the remuneration received by such an individual is exempt from Canadian taxation by virtue of paragraph 2 of Article XV of the Convention. ...

16 July 1996 External T.I. 9604915- 55(2)-NOT APPLY WHERE SALE & REDMPTION DIFFERENT SERIES.-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Where preferred shares issued by Newco on the roll-in to Newco of shares of Opco, have a dividend entitlement equal to dividends received by Newco on the shares of Opco, and to proceeds received by Newco on the sale of shares of Opco to the extent of the gain realized by Newco, but with the redemption amount of the shares being reduced on a dollar-for-dollar basis by the amount of the dividends paid out of such gain. ...

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. ...

5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F- entreprise exploitée activement – revenu de location-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business principal purpose means main or chief objective In the course of a general discussion as to whether a Canadian-controlled private corporation with rental properties carried on an active business, CRA stated (before referring to the more-than-five full time employee test): A "specified investment business" is essentially a business, including a business of leasing real or immovable property, the principal purpose of which is to derive income from property, including rents. ...

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). ...

26 March 2001 External T.I. 2001-0073495- MANUFACTURING & PROCESSING-- summary under Canadian Manufacturing and Processing Profits Summary Under Tax Topics- Income Tax Act- Section 125.1- Subsection 125.1(3)- Canadian Manufacturing and Processing Profits After noting that the "processing of goods usually refers to a technique of preparation, handling or other activity designed to effect a physical or chemical change in an article or substance, other than natural growth", and that examples included galvanizing iron, dyeing fence posts, dehydrating foods and modernizing and pasteurising dairy products, the Agency indicated that "a recycling facility would generally qualify for the manufacturing and processing profits deduction.... ...

& 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. ...