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Bundle Date Translated severed letter Summaries under Summary descriptor 2024-01-31 2023 Ruling 2022-0955451R3 F- Post mortem pipeline Income Tax Act- Section 84- Subsection 84(2) conventional post-mortem pipeline transaction 22 June 2023 External T.I. 2018-0746741E5 F- Eligible dividend allocation Income Tax Act- 101-110- Section 104- Subsection 104(19) eligible and non-eligible dividend can be wholly designated to two respective beneficiaries Income Tax Act- 101-110- Section 104- Subsection 104(13) a discretionary trust can wholly allocate each of an eligible and a non-eligible dividend to each of two recipient beneficiaries 2002-04-26 22 May 2002 Internal T.I. 2001-0106577 F- APPARIEMENT DES REVENUS ET DEPENSES Income Tax Act- Section 9- Timing following Canderel, an upfront payment made under a multi-year supply contract is currently deductible 14 May 2002 Internal T.I. 2001-0109517 F- SECTION DE LA LOI248(28) Income Tax Act- Section 248- Subsection 248(28) disallowance of interest deduction to partnership on loans to corporate partners whose amount was included in their income under s. 15(2), was not contrary to s. 248(28) 8 May 2002 Internal T.I. 2002-0135737 F- REGIME DE CONGE A TRAITEMENT DIFFERE Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(vi) s. 6(11) income recognition when apparent that the leave would not commence within 6 years/ Reg. 6801(a)(vi) does not to extend 6-year period but deals with leaves over one year 2002-04-12 3 May 2002 External T.I. 2001-0110145 F- avantage imposable-vetements Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) reimbursing a professor for a briefcase needed in connection with work would be non-taxable 3 May 2002 External T.I. 2002-0132615 F- PERTE DECOULANT D'UN PAIEMENT A UN RPDB Income Tax Act- Section 147- Subsection 147(8) creation of a business loss from making a DPSP contribution is not necessarily inconsistent with the DPSP rules 1 May 2002 External T.I. 2002-0133145 F- RAP- BAIL & ACTIONS Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home ...

Reg. 402(5), which provides that, for Reg. 402(3) purposes, corporate gross revenue does not include interest on bonds, debentures or mortgages, dividends- or rentals or royalties from property that is not used in connection with the principal business operations – is broadly interpreted by CRA to also extend to interest on promissory and other notes, bankers’ acceptances, intercompany loans, certificates, guaranteed investment certificates, and any unsecured debt instruments. ...

EMPLOI Income Tax Act- Section 60- Paragraph 60(n)- Subparagraph 60(n)(iii) repayment of EI benefits due to award of wrongful dismissal damages was deductible under s. 60(n)(iii) Income Tax Act- Section 60- Paragraph 60(v.1) repayment of EI benefits due to award of wrongful dismissal damages was deductible under s. 60(n)(iii) rather than s. 60(v.1) 14 March 2002 External T.I. 2002-0119695 F- Income & Losses/Business or Property General Concepts- Agency criteria applied for determining presence of agency 12 March 2002 External T.I. 2002-0125885 F- Section 55(3)(a)- Exception55(3)(a) Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a) s. 55(3)(a) applies where Opco redeems 50% shareholder (Holdco A) where other shareholder is owned by the son respecting the spousal trust owning Holdco A ...

These are additions to our set of 2,812 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 2,819 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¼ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-01-04 9 January 2002 External T.I. 2001-0089655 F- AVANTAGE AUTOMOBILE Income Tax Act- Section 248- Subsection 248(1)- Automobile- Paragraph (e)- Subparagraph (e)(i) 6-seat pickup not excluded from 90% test Income Tax Act- Section 6- Subsection 6(2) being on-call at home does not diminish the personal benefit from use 10 January 2002 External T.I. 2001-0090325 F- UTILISATION DES VEHICULES Income Tax Act- Section 6- Subsection 6(2) commuting in connection with employer requirement to keep vehicle overnight at home was personal use – but not emergency use 18 January 2002 External T.I. 2001-0092665 F- AUTOMOBILE-VEHICULE PUBLICITAIRE Income Tax Act- Section 248- Subsection 248(1)- Automobile automobile status turns on design, not use (here, only for advertising) Income Tax Act- Section 248- Subsection 248(1)- Automobile- Paragraph (e)- Subparagraph (e)(i) vehicle cosmetically altered for advertising purposes is not thereby used to transport goods or equipment 8 January 2002 External T.I. 2001-0094485 F- EMPLOI SUR UN CHANTIER PARTICULIER Income Tax Act- Section 6- Subsection 6(6)- Paragraph 6(6)(a) s. 6(6) applicable to a non-citizen 21 January 2002 External T.I. 2001-0078735 F- Droit de recevoir une somme Income Tax Act- Section 54- Proceeds of Disposition FMV of contingent right to deferred cash sales proceeds was included in proceeds, with subsequent gain or loss when the contingency was resolved Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(g) s. 12(1)(g) inapplicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration declined in value Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(f) s. 85(1)(f) applicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration received under s. 85(1) declined in value 21 January 2002 External T.I. 2001-0080325 F- FRAIS DE VOYAGE-BIENS LOCATIFS Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(h) notwithstanding s. 18(1)(h) jurisprudence, CCRA allows travel expenses incurred for collecting rent, supervising repair work or managing the multiple rental properties ...

These are additions to our set of 2,831 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,879 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,886 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,892 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 ¾ years of releases of such items by the Directorate. ...