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5 December 2022 External T.I. 2021-0915921E5- ELHT – Class of beneficiaries-- summary under Subparagraph 144.1(2)(e)(i) Summary Under Tax Topics- Income Tax Act- Section 144.1- Subsection 144.1(2)- Subparagraph 144.1(2)(e)(i) employee beneficiaries of a mooted EHLT form a single class if their benefit entitlements are reasonably similar A corporation (“Corporation”) operating a Canadian retail chain, and the over-1,000 stores that owned it settled a health and welfare trust (the “Trust”) providing health benefits to employees ol the Corporation (representing 22% of all employees under the Trust) and employees of Member stores and affiliates as to the balance. ... CRA responded: The term “class of beneficiaries” is defined in subsection 144.1(1) of the Act (for purposes of section 144.1 of the Act) as a group of beneficiaries with identical rights or interests under the trust. … [A] “right”, as it pertains to an ELHT, includes an entitlement to designated employee benefits (“DEBs”). ...

6 September 2023 Internal T.I. 2019-0805481I7- Interaction of 17.1(1) & 247(2)-- summary under Subsection 17.1(1) Summary Under Tax Topics- Income Tax Act- Section 17.1- Subsection 17.1(1) interest can be imputed under s. 247(2) to a PLOI which already is subject to s. 17.1 imputed interest A corporation resident in Canada (“CRIC”) made various loans to an indirect wholly-owning parent which bore interest, payable at least annually, at a floating rate equal to the prescribed rate under Reg. 4301(b.1), with a timely joint election under s. 15(2.11) being made by them for each of those loans to qualify as a “pertinent loan or indebtedness” for the purposes of ss. 15(2) and 17.1(1). ... In short … subsection 247(2), which was broadly worded to embody the arm’s length principle, was meant to apply to all cross-border transactions, arrangements or events, including financial transactions, between non-arm’s length persons or partnerships, unless a specific exclusion applies. ...

2018 Ruling 2018-0740931R3 F- deductibility of interest – convertible debentures-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on borrowed money used to pay a premium on the cash redemption of convertible debentures is deductible Proposed transactions ACo, a listed Canadian public company, whose outstanding convertible debentures (the “Debentures”) are about to mature, will borrow from a lender (BCo) under “Loan 3.” ... However, upon receiving the notices of redemption for the Debentures, ACo will have the right to redeem such Debentures for an amount corresponding to the market value of the ACo shares into which they are convertible – which it will do, using proceeds of Loan 3 and thereby paying a “Conversion Premium C” over the redeemed Debentures’ principal amount. ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) the forgivable loan portion of a CEBA loan is a s. 12(1)(x)(iv) receipt The Canada Emergency Business Account (“CEBA”) provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... This is also the case where the taxpayer made a subsection 12(2.2) election to reduce the paragraph 12(1)(x) inclusion in the year of receipt. … ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Gross Revenue Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Gross Revenue Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146(5) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(5) The payment of administration or management fees by an annuitant will constitute the payment of a premium to the RRSP. ...

1993 External T.I. 9335545 F- Sub — 256(2) and T2144-- summary under Subsection 256(2) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(2) Re RC's requirements for acceptance of a late-filed Form T2144. ...

16 August 1995 External T.I. 9512405- VESSELS- PARTIAL DISPOSITION & 13(16) ELECTION-- summary under Subsection 13(16) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(16) A partial disposition of a vessel will qualify as a disposition of a vessel for purposes of s. 13(16). ...

TREATY & LIFE INSURANCE PROCEEDS-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 The word "gains" in article XIII of the Canada-U.S. ...