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Technical Interpretation - Internal summary

22 May 2009 Internal T.I. 2009-0312791I7 F - Transfert de biens entre un rentier et son REÉR -- summary under Paragraph 251(1)(c)

22 May 2009 Internal T.I. 2009-0312791I7 F- Transfert de biens entre un rentier et son REÉR-- summary under Paragraph 251(1)(c) Summary Under Tax Topics- Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) an RRSP trust’s annuitant does not deal at arm’s length under s. 251(1)(c) with the RRSP Before finding that the purchase of RRRSP property (the “Co-op” shares) by the RRSP’s annuitant at cost was to be treated as the payment of a premium by the annuitant to the extent of the excess over the property’s fair market value, CRA stated: You advised us that the annuitant and the trust that governs the annuitant’s RRSP are not related persons within the meaning of paragraph 251(1)(b), since the trust is described in paragraph (a) of the definition of "trust" in subsection 108(1) …. However the fact that the annuitant and his RRSP are not deemed to be related persons under paragraph 251(1)(b) does not mean that they are not otherwise not dealing with each other at arm's length at any particular time within the meaning of paragraph 251(1)(c). ... In any event, the very fact that the annuitant is prepared, in order to acquire units of the Co-op from the RRSP, to pay an amount that exceeds their FMV, which is nil confirms in our view that the annuitant and the trust governing the RRSP do not deal at arm's length in this transaction. ...
Technical Interpretation - External summary

23 December 2008 External T.I. 2008-0271401E5 F - GRIP/CRTG -- summary under Element G

However, CRA accepts that the portion of the dividend that may be considered safe income on hand attributable to the gain on the shares may be included in the GRIP of the corporation receiving the dividend if the corporation designates such amount as a separate taxable dividend under paragraph 55(5)(f). ...
Technical Interpretation - External summary

21 December 2004 External T.I. 2004-0091011E5 F - Déductibilité-primes d'assurance-responsabilité -- summary under Start-Up and Liquidation Costs

CRA responded: [Under] the principle in Poulin an expense paid in a year in which a taxpayer is no longer carrying on business may be deducted in that year since the taxpayer cannot be considered to have ceased to carry on business as long as the taxpayer is engaged in following up on actions taken by the taxpayer in the course of carrying on business. [P]remiums paid by a taxpayer to maintain liability insurance in respect of actions taken in the course of carrying on the taxpayer's business would be deductible in computing the taxpayer's income. ...
Technical Interpretation - Internal summary

5 September 2018 Internal T.I. 2017-0698241I7 - Interpretation of subsection 93(4) -- summary under Subsection 93(2.01)

5 September 2018 Internal T.I. 2017-0698241I7- Interpretation of subsection 93(4)-- summary under Subsection 93(2.01) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(2.01) s. 93(2.01) applied to capital loss resulting from s. 94(3) basis bump But for s. 94(3), a Canadian corporation (ACo) would have realized a capital loss of $1 million on the liquidation and dissolution of a wholly-owned non-resident subsidiary (FA1) which, in turn, held FA2 and FA3.After the Directorate found that s. 94(3) applied to deny the loss and add it to the ACB to ACo of the shares of FA2 and FA3, it then considered the question: If the portion of such denied loss added to the ACB of the FA2 shares under s. 93(4)(b) was $50,000 (resulting in ACo’s ACB of the FA2 shares becoming $100,000 (as otherwise determined under s. 88(3)) + $50,000 = $150,000), would the s. 93(2.01) rules determine ACo’s loss on the disposition of the FA2 shares? ... Absent the subsection 93(2.01) loss limitation rule, ACo would have an otherwise determined (capital) loss of $40,000 (i.e. $110,000- $150,000) arising on its disposition of its FA2 shares …. ...
Technical Interpretation - Internal summary

28 May 2019 Internal T.I. 2018-0772971I7 - Interaction between sections 94, 17, 247 -- summary under Paragraph 94(2)(a)

. Since LLC1 borrowed funds in a situation where there was no cost to LLC1, the fair market value of the shares of LLC1 have increased as a result of the non-interest bearing loan. Therefore at the time the non-interest bearing loan is made, there is an increase in the fair market value of the shares of LLC1 held by NRTrust. ...
Technical Interpretation - External summary

28 June 2022 External T.I. 2022-0933661E5 - Meaning of Disposition -- summary under Disposition

In addition, you have advised that there is no change in the capital structure of the Corporation, the number of outstanding shares, the number of shares held by any shareholder, or the interest, rights, or privileges attached to any share. [Accordingly] …. the actions undertaken would not, in and of themselves, constitute a redemption, acquisition, or cancellation of any share of the Corporation, or otherwise result in a disposition of a share of the Corporation. ...
Technical Interpretation - Internal summary

9 July 2024 Internal T.I. 2023-0976691I7 - Film Tax Credit and Alter Ego Trust -- summary under Subparagraph (b)(iii)

The Directorate noted that the relevant BC ITA provisions were modeled on ITA s. 125.4(1) labour expenditure (b)(iii) and s. 125.5(1) Canadian labour expenditure- (b)(iii). In finding that this shareholding satisfied the above “belong to” test, rather than the shares belonging to the trust under the position of the TSO, the Directorate stated: [T]he shares belong to [the individual] and not the Trust for purposes of the tax credit. ...
Conference summary

5 October 2018 APFF Roundtable Q. 9, 2018-0768801C6 F - Tax on Split -- summary under Subparagraph (a)(i)

5 October 2018 APFF Roundtable Q. 9, 2018-0768801C6 F- Tax on Split-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares- Paragraph (a)- Subparagraph (a)(i) portfolio investment company might qualify as having a business 2018 STEP Roundtable Q.6 and Q.7 confirmed that the shares of a holding company (or of a company generating no business income) cannot qualify as excluded shares, whereas Examples 8 to 12 of CRA’s Guidance on the application of the split income rules for adults and the Department of Finance’s Technical Backgrounder on Measures to Address Income Sprinkling provide that such shares so qualify. ... CRA stated: The CRA's response to [Q.7] …was based on the assumption made in the statement of that question that the corporation had no business income. …[In its Guidance] to demonstrate that the various exclusions were applicable to entities carrying on a business whose principal purpose is to derive income from property, including interest, dividends, rents and royalties, such as investment management corporations (in Examples 8 and 12), the CRA assumed that these corporations maintained a sufficient level of activity such that their income could be considered as derived from such a business. ... X, her shares are “excluded shares” if such $100,000 of income was “derived from the carrying on of a business the purpose of which is to earn interest income and dividends notwithstanding the fact that the capital used in the acquisition by Holdco of the property used in carrying on its business was derived from dividends received from Opco.” ...
Technical Interpretation - External summary

25 March 2009 External T.I. 2008-0300401E5 F - Fiducie en faveur de soi-même - prêt sans intérêt -- summary under Subsection 75(2)

X in the hypothetical situation …. The inapplicability of this provision arises from the terms of the loan [being] determined independently of the terms of the trust indenture, as confirmed in Howson …. ...
Conference summary

7 October 2022 APFF Roundtable Q. 7, 2022-0942731C6 F - Permanent establishment and teleworking -- summary under Subsection 102(1)

After indicating that the employer likely would not have a deemed permanent establishment in Ontario by virtue of this arrangement unless the employer was carrying on business in Ontario through the cottage, CRA went on to state: Even if the CRA were to conclude that Mr. ... X's remuneration. [T]he deeming rules in I.T.R. subsection 400(2) do not extend to I.T.R. sections 100 and 102, which are relevant to determining whether an employee reports for work at an establishment of the employee’s employer located in a particular province, as well as in determining the amounts to be deducted or withheld by the employer from the employee's remuneration. ...

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