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2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Paragraph 212(4)(a) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(4)- Paragraph 212(4)(a) management of on-line store A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ...

2011 Ruling 2011-0416891R3- Fees for Digital Content & Management Services-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 A US LLC ("Corporation C"), whose sole member was a US corporation qualifying for benefits under the Canada-US Convention, ran a platform for the provision of "Digital Content" (movies, television shows, music videos, documentaries and similar audio-visual content) which it (and affiliated corporations) were permitted to distribute under content licence agreements with the third-party holders of the copyright. ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares premium for voting rights The questioner referenced the CRA statement at the 2009 British Columbia Tax Conference that, in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of the estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, CRA generally accepts that no premium should be attributed to such shares in determining their fair market value under s. 70(5), and asked whether this position also applies for the purposes of s. 104(4)(a), e.g., re the deemed disposition arising on the death of the spouse who is the beneficiary of a spousal trust. ...

2 July 2013 External T.I. 2012-0454251E5- 149(1)(l) – donations to capital fund-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) sale of naming rights Generally, an organization referred to under s. 149(1)(l) will not lose its s. 149(1)(l) exemption for collecting donations from members or from businesses affiliated with its members for use in a capital project that furthers the organization's non-profit purposes, nor will it lose its exemption for maintaining a "wall of honor," naming rights, or similar systems for recognizing such contributions, providing that such recognition has only nominal value. ...

4 December 2013 External T.I. 2012-0465891E5 F- Primes d'assurance / Premiums-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sub plan with only one employee of particular employer could be a group plan if benefits similar to those for employees in other sub plans The employees of Corporation A were members of four basic insurance plans respecting health insurance, salary insurance and accidental death and dismemberment insurance available to employees of employers in a particular industry. ...

28 May 2015 IFA Roundtable Q. 5, 2015-0581531C6- IFA 2015 Q.5: "Causality test" in 18(6) & 212(3.1)-- summary under Paragraph 18(6)(c) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6)- Paragraph 18(6)(c) "because of" causality test What is the requisite degree of linkage referenced by the "because" test in clause (B) of ss.18(6)(c)(i), 18(6)(c)(ii), 212(3.1)(c)(i) and 212(3.1)(c)(ii) (the "Clause B causality tests") between a debt owing by the taxpayer to a creditor and a secondary obligation existing between that creditor (or someone not dealing at arm's length with that creditor) and certain non-residents, so as to engage s. 18(6.1) or 212(3.2)? ...

16 June 2014 STEP Roundtable, 2014-0523091C6- STEP CRA Roundtable – June 2014-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) bequests to both spouse and common law spouse Can s. 70(6) apply to a transfer by a taxpayer both to his or her spouse and a transfer to his or her common law spouse? ...

4 March 2015 External T.I. 2014-0562151E5 F- Frais de psychothérapie – dépense d'entreprise-- summary under Income-Producing Purpose Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose “but for” test applied to determine deductibility/potentially creditable item can instead be expense In the course of a business of offering psychology services, a psychologist incurs psychotherapy fees in order to reduce such therapist's personal reaction to the sessions conducted with clients. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Subsection 20(12) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(12) no s. 20(12) deduction available where only a capital gain A deemed-resident s. 94 trust realized a capital gain and incurred gains tax of $10,000 for U.S. purposes on disposing in the U.S. of marketable securities but, for purposes of the Act, realized capital gains of only $20,000 (with Canadian tax thereon of $2,900) due to the securities' ACB previously having been stepped up under s. 128.1(1)(c). ...

12 July 2013 External T.I. 2011-0415911E5- FA held through partnership-– 95(2)(m) & 95(2)(y)-- summary under Paragraph 95(2)(m) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(m) Canco has a 51% interest in a partnership ("Partnership") holding all the shares of Forco1 which, in turn, owns all the shares of Forco2. ...