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11 February 2011 External T.I. 2010-0386651E5 F- Admissibilité- Frais médicaux-- summary under Paragraph 118.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) preliminary report of genetic counsellor would not qualify In response to a query of the manager of a health care spending account as to whether an expenditure qualified under s. 118.2(2), CRA stated: [A]lthough … it is difficult … to comment on the application of [s. 118.2(2)(a)] with respect to costs related to a preliminary report of a genetic counsellor to establish the risk of breast cancer, we would generally be of the opinion that such costs are not incurred for maintaining health, preventing disease and diagnosing or treating an injury, illness or disability. ...

Without providing detailed analysis, CRA indicated that this asset was not excluded under s. 233.3(1) – specified foreign property – para. ...

.” … In this case … only interest at the legal rate and the additional compensation provided for in the Civil Code of Quebec accrued since the date of the judgments of the Superior Court of Quebec must be included in the calculation of the plaintiffs' income under paragraph 12(1)(c). ...

Respecting Scenario 1, the Directorate stated: Individual A and Individual B form a related group that controls the Employer and are both related to the Employer pursuant to paragraph 251(2)(b) … [so that] the definition of IPP … is satisfied. Respecting Scenario 2: [A]s is apparent from Duha, the determination of whether a person exercises de jure control … must also take into consideration whether any specific or unique limitation on a shareholder’s power to control the election of the board or the board’s power to manage the business and affairs of the company, is manifested in either the constating documents of the corporation, or any unanimous shareholder agreement. Therefore, it is possible that … Individual A or Individual B could … possess de jure control of the Employer and be related to the Employer under subparagraph 251(2)(b)(i). … If Individual A or Individual B possessed a right such that the individual would be deemed to own sufficient shares to control the Employer under paragraph 251(5)(b), then the individual would be related to the Employer under subparagraph 251(2)(b)(i). ...

A's loss is not a "superficial loss" …. [T]he RRSP trust under which Ms. ... However, the RRSP trust does not own the substituted property or have the right to acquire it at the end of the [30-day] period …. ... B's RRSP trust had instead reacquired the shares on October 2, 2021 … subparagraph 40(2)(g)(i) would not apply …. ...

After noting that “ Redclay [indicated that] ‘ was payable’ requires any GST/HST or PST actually paid pursuant to a vehicle purchase or lease contract to be included in the definition of cost for the purposes of subsection 6(2),” CRA indicated that under ETA s. 153(4)(c) “the GST/HST paid is not reduced because of an exemption [as referred to in s. 6(7)] but is reduced because of a calculation of the GST/HST base,” and the same analysis appeared to apply in the PST provinces. ...

After noting that "paragraph 107(1.1)(b) would not deem the cost of the interest in the Trust of the estate to be nil because it would acquire the interest from a person who was the beneficiary immediately before such acquisition," and that under s. 108(1) – "cost amount" – (a), "the cost amount of the [estate's] interest in the Trust was deemed to refer to the cost amount, immediately before the distribution, of each of the properties distributed to the beneficiary," CRA stated (TaxInterpretations translation): …as in this case, the cost amount of the Property to the Trust would correspond to the cost amount to the estate of the capital interest in accordance with subsection 108(1), the application of paragraph 107(2)(b) would ensure that the cost of the property to the estate would be equal to the ACB of its capital interest, and thus, generally, to its cost determined in accordance with paragraph 70(5)(b). ...

The Income will be added to the exempt earnings of the FA5 Subsidiary pursuant to Reg. 5907(1) – exempt earnings – s. ...

CRA summarized the rules under s. 118.1(5.1)(b) and s. 118.1(1) – charitable gift – para. ...

This letter represents a change to CRA’s position … [in 2008-0297161E5] …. ...