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14 March 2002 External T.I. 2002-0119695 F- Income & Losses/Business or Property-- summary under Agency Summary Under Tax Topics- General Concepts- Agency criteria applied for determining presence of agency Before confirming that ticket sales receipts of the taxpayer may have been generated as agent for charitable organizations, so that they did not generate income to the taxpayer, CCRA stated: In general, the CCRA agrees to recognize a principal-agent relationship between persons for tax purposes provided that: the relationship between the persons concerned is legally one of principal-agent; this implies, among other things, that the transactions relating to the agency are effective and complete from a legal standpoint; this relationship arises from a prior formal agreement and does not constitute an ex post facto arrangement; this relationship does not contravene any legislation; the relationship is not a sham; the relationship is disclosed to the CCRA and the relevant documents are provided to the CCRA at the appropriate time (generally when the relevant tax returns are filed); the facts of the particular situation support the existence of the principal-agent relationship between the persons concerned. ...

7 January 2004 Internal T.I. 2003-0038217 F- gain en capital / résidence principale-- summary under Paragraph 45(1)(c) Summary Under Tax Topics- Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(c) no partial change of use of residence where rental operation was not a business, or the business was ancillary A taxpayer constructed a housing unit for his son and son's spouse on the second floor of his personal residence and incurred small losses in renting it out to him. ...

7 January 2004 Internal T.I. 2003-0038217 F- gain en capital / résidence principale-- summary under Business Source/Reasonable Expectation of Profit Summary Under Tax Topics- Income Tax Act- Section 3- Paragraph 3(a)- Business Source/Reasonable Expectation of Profit rental of second floor of house to son at cost was not a business A taxpayer constructed a housing unit for his son and son's spouse on the second floor of his personal residence and incurred small losses in renting it out to him. ...

1999 Ruling 9903543- TOTAL RETURN SWAPS & MUTUAL FUND TRUST-- summary under Subsection 18.1(15) Summary Under Tax Topics- Income Tax Act- Section 18.1- Subsection 18.1(15) 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). ...

27 November 2018 CTF Roundtable Q. 13, 2018-0779991C6- 20(1)(c) & Triangular Amalgamation-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by parent for use in connection with a triangular amalgamation to redeem preferred shares issued by Target can be deductible In a triangular amalgamation, is the interest on a third party loan obtained by ParentCo to redeem preferred shares issued by TargetCo as part of the transaction deductible under s. 20(1)(c)? ...

15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6- 78(1)(b)(ii) deemed loan & thin capitalization-- summary under Subparagraph 78(1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 78- Subsection 78(1)- Paragraph 78(1)(b)- Subparagraph 78(1)(b)(ii) deemed s. 78(1)(b)(ii) loan is not also deemed to bear interest The thin cap rules apply to “outstanding debts to specified non-residents”, whose definition specifies that there is deductible interest paid or payable on them. ...

7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician-- summary under Income or Loss Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4)- Income or Loss royalty income was incident to composing active business Gagliese Productions found that a company which earned royalties from the daily activities of its sole shareholder and employee in writing and producing music for TV episodes was earning income from an active business rather than from a specified investment business. ...

2020 Ruling 2019-0799981R3- Disposition – Reclassification and Stock Split-- summary under Subsection 116(1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(1) no s. 116 certificate required for simultaneous consolidation of multiple identical series into one series, and stock split With a view to going public, a closely-held US corporation, whose issued and outstanding shares (which were taxable Canadian property and held by Canadian and US-resident corporate shareholders) consisted of seven series of common shares with identical attributes, proposed to amend its articles of incorporation so as to reclassify all the common shares into one series and to simultaneously effect a stock split. ...

8 July 2020 CALU Roundtable Q. 2, 2020-0842141C6- Return of premiums on death & CDA-- summary under Paragraph (j) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(9)- Disposition- Paragraph (j) a refund of premiums on death under a life insurance policy does not entail its disposition A private corporation is the owner and beneficiary of an exempt life insurance policy (with an adjusted cost basis of $90,000) on the life of a shareholder, who dies from, say, suicide or skydiving, which does not void the policy, but instead results in the insurer repaying all premiums ($100,000). ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 4, 2020-0851621C6 F- RRSP or RRIF on death – Joint election-- summary under Subsection 146.3(6.1) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6.1) specific bequest of RRIF is treated as passing through the estate’s hands, so that a s. 146.3(6.1) election is necessary Where a RRIF is the subject of a specific bequest made to the deceased annuitant's spouse under a Quebec will and the RRIF proceeds are distributed by the RRIF issuer directly to the surviving spouse, CRA considers that the RRIF proceeds passed through the estate rather than coming directly out of the RRSP, as required under the “designated benefit” definition. ...