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Bundle Date Translated severed letter Summaries under Summary descriptor 2004-10-29 8 October 2004 Internal T.I. 2004-0093371I7 F- Crédit d'impôt à l'investissement & impôt minimum Income Tax Act- Section 127- Subsection 127(5)- Paragraph 127(5)(a)- Subparagraph 127(5)(a)(ii) carryback of ITCs from year where the taxpayer was subject to minimum tax 19 October 2004 Internal T.I. 2004-0094971I7 F- Programme de formation admissible Income Tax Act- Section 118.6- Subsection 118.6(1)- Qualifying Educational Program “period” referred to the times at which the individual was receiving income from employment 28 September 2004 Internal T.I. 2004-0079801I7 F- Pension alimentaire Income Tax Act- Section 56.1- Subsection 56.1(4)- Support Amount settlement of support arrears are not deductible or includible 30 September 2004 Internal T.I. 2004-0083301I7 F- Entreprises distinctes Income Tax Act- Section 4- Subsection 4(1)- Paragraph 4(1)(a) 2 different centres were branches of the same business 30 September 2004 Internal T.I. 2004-0085051I7 F- Intérêts et indemnité additionnelle Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) indemnity under CCQ Art. 1619 was pre-judgment interest Income Tax Act- Section 129- Subsection 129(4)- Income or Loss interest on damages relating to lost business was active business income 19 October 2004 Internal T.I. 2004-0085711I7 F- Dommages suite à une entente hors cour Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance amount received in settlement of grievances and on agreeing to retire was a retiring allowance in the absence of evidence that it was for harassment or unpaid wages Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(n) required repayment of excess amount of wage loss insurance previously received could give rise to s. 8(1)(n) deduction 20 October 2004 Internal T.I. 2004-0086501I7 F- Droits compensateurs Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(vv) posting of bonds for US countervailing duties did not constitute their being “paid” for s. 20(1)(vv) purposes Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(e) obligation to repay suppliers for extra US countervailing duties charge made to them was contingent until a board decision reversed such duties 8 October 2004 APFF Roundtable Q. 11, 2004-0090791C6 F- Maladies graves et soins de longue durée Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sickness plan can comprise individual critical illness policies Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) periodic payments under long-term care insurance are not taxable Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose premiums for critical illness policies and individual long-term care policies for senior employees are deductible ...

These are additions to our set of 2,125 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 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,134 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 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,143 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 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,151 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 17 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,216 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 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,257 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 18 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,271 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 18 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,290 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 18 ¾ years of releases of such items by the Directorate. ...

Income Tax Act- Section 246- Subsection 246(1)- Paragraph 246(1)(a) s. 246(1)(a) application re mother’s use of a car of Opco controlled by her son’s Holdco to her rather than son turned on whether her minority Holdco had significant influence over Opco Income Tax Act- Section 15- Subsection 15(5) application of s. 15(5) to shareholder’s use of company automobile Income Tax Act- Section 10- Subsection 10(1) automobiles in car dealer inventory used for employee’s personal use remained in inventory, cf. if converted primarily to personal use of shareholder (which would not be a disposition) Income Tax Act- Section 9- Computation of Profit conversion of automobile in car inventory to personal use of CEO would not entail its deemed disposition nor would the conversion of car inventory to personal use of shareholders 2003-11-07 30 October 2003 External T.I. 2003-0037465 F- Subsections 40(3.3) & 40(3.4) Also released under document number 2003-00374650. ...