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14 March 2017 External T.I. 2016-0656101E5 F - Death Benefit -- summary under Death Benefit

. … After indicating that when the amount was recorded in the minutes did not affect its character, CRA stated that “the payment of the death benefit may be staggered over more than one taxation year.” ...

31 March 2017 External T.I. 2016-0630351E5 - Return of a gift -- summary under Subsection 118.1(26)

. … Where the original property is returned, the taxpayer is deemed not to have disposed of the property nor to have made a gift. ...

31 March 2017 External T.I. 2016-0630351E5 - Return of a gift -- summary under Charitable Foundation

. … [T]he determination of whether the gift of the life insurance policy to the foundation was subject to a condition subsequent or whether the foundation can legally return the life insurance policy is a question of law and beyond the scope of this technical interpretation. ...

15 May 2017 External T.I. 2016-0645891E5 F - Services rendered to a State -- summary under Article 18

. … [T]he exercise by a person of duties as a nurse within the Swiss healthcare sector, which is essentially dedicated to the provision of services for the benefit of the community as a whole, does not generally [so] qualify…. ...

31 March 2009 External T.I. 2009-0310821E5 F - Associated Corporations - 256 -- summary under Paragraph 256(1)(d)

. … [I]n order to determine whether B is related to each member of the group that controls AB Inc., B, as owner of shares of the capital stock of B Inc. and AB Inc., would be deemed, as a shareholder of B Inc., to be related to himself as a shareholder of AB Inc. by virtue of subsection 256(1.5). ...

30 April 2009 External T.I. 2008-0296721E5 F - Late filed election 85(7) - Amending transactions -- summary under Subsection 85(1)

[E]ven if the "deed of correction" of the Contract …were to be entered into … CRA could not take it into account for the purposes of determining the tax consequences of the transfer of the Immovable. ...

7 June 2017 External T.I. 2016-0671731E5 F - Transfer of life insurance policy by dividend in kind -- summary under Paragraph 148(7)(a)

. … We have brought this situation to the attention of the Department of Finance. ...

27 April 2009 External T.I. 2008-0304761E5 F - Retraits et transferts provenant d'un RPDB -- summary under Subsection 147(19)

. … [T]he provisions in paragraph 147(2)(k) and subsection 147(19) apply even if the members are employees when withdrawing or transferring funds from a DPSP. ...

4 May 2009 External T.I. 2008-0299841E5 F - Garantie pour l'impôt de départ -- summary under Subsection 220(4.5)

. … [However] in the hypothetical situation described above, the individual could benefit from a refund of overpaid instalments of $10,000 for the individual’s 2002 taxation year. ...

4 May 2009 External T.I. 2008-0299841E5 F - Garantie pour l'impôt de départ -- summary under Subsection 164(7)

. … In this respect, the provision of sufficient security does not constitute a payment. ...

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