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6 March 2023 External T.I. 2023-0960631E5- MHRTC – Pre renovation Unedited CRA Tags ITA: Section 122.92, Subsections 122.92(1), (3) and (4). ...

12 September 2022 External T.I. 2021-0886441E5- Restricted Stock Unit Plan – Adjusted Cost Base Unedited CRA Tags Subsection 5(1), paragraph 6(1)(a), section 7, subsection 7(1.3), subsection 7(1.31), subsection 40(1), paragraph 40(2)(g), subsection 47(1), subsection 47(3), paragraph 53(1)(f) Principal Issues: How to calculate the adjusted cost base to an employee, and the corresponding capital gain resulting from a partial disposition, of shares acquired on the settlement of vested restricted stock units where the employee already owns identical shares. ...

9 August 2024 External T.I. 2023-0969381E5- XXXXXXXXXX – Allowance Unedited CRA Tags 5(1); 6(1)(a); 6(1)(b); 56(1)(n); ITR 200(1) Principal Issues: The tax treatment and reporting requirements of allowance payments from the XXXXXXXXXX to recruits. ...

29 August 2024 External T.I. 2024-1022841E5- Indian Act Tax Exemption & Employment Income Unedited CRA Tags ITA para. 81(1)(a); IA s. 87 Principal Issues: Whether the employment income of a First Nations individual is situated on a reserve and exempt from income tax under section 87 of the Indian Act and paragraph 81(1)(a) of the Income Tax Act. ...

16 November 2011 External T.I. 2011-0419191E5- Foreign Intermediaries & Canadian Owners Unedited CRA Tags S. 212, 215; Regulations 201, 202 Principal Issues: A Canadian Financial Institution (CFI) provides securities custody services to foreign financial intermediaries (FFI). ... While this case was primarily about the application of interest accrued on account of a failure to withhold and forthwith remit the tax even though the principle tax amount was reduced to nil through the payee's election to be taxed under Part I, the Tax Court judge addressed the nature of the withholding and remitting system and the Canadian payers' consequential obligations; see especially paragraphs 23-27 of the TCC judgment. 2 Pending updates to IC76-12, Applicable rate of part XIII tax on amounts paid or credited to persons in countries with which Canada has a tax convention related to forms NR301, NR302, and NR303, online: < http://www.cra-arc.gc.ca/formspubs/frms/ic76-12r6-eng.html>. ...

20 October 1994 External T.I. 9404575- FARM & CAPITAL GAINS Unedited CRA Tags 28(1) 43.1 73(3) 85(C.2) 40(3) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues: VARIOUS FARM & CAPITAL GAINS ISSUES. Position TAKEN: VARIOUS Reasons FOR POSITION TAKEN: DEPARTMENT'S POSITION. 940457 XXXXXXXXXX W.P. ...

20 November 2003 External T.I. 2003-0029355- GHOST CARS & MUNCIPAL AUTOS Also released under document number 2003-00293550. ... Likewise, the operating cost benefit computed under paragraph 6(1)(k) should be relatively minor, where personal travel is not significant (whether the benefit is based on 17 ¢ per kilometre, or the officer elects to base the calculation on one-half of the standby charge). ...

The Tax Court of Canada determined that the funds that had been loaned, effectively, to the government would probably have otherwise been used in the taxpayer's M & P activities and therefore concluded that the refund interest was properly included in its adjusted business income for purposes of computation of the M & P tax credit. ... This case is important because refund interest received by companies (except companies that have resource activity) would be taxed at the lower income tax rate that applies to M & P companies. ... These amendments were not to be construed as implying that the receipt of refund interest previously had the result of increasing entitlement to the M & P deduction. ...

18 December 2008 External T.I. 2008-0300731E5- Costs of Clearing Land / Replanting Unedited CRA Tags 9(1); 18(1)(b); 30 Principal Issues: 1. ...

26 June 1997 External T.I. 9600175- DIVIDEND & BONUS PAID TO INDIAN SHAREHOLDER Unedited CRA Tags 67 81 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...