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27 April 2004 External T.I. 2003-0048351E5 F - Prestation de décès versée par la RRQ -- summary under Paragraph 56(1)(a.1)

If, according to the T4A (P) slip issued by the RRQ, the death benefit was paid to the "heirs …” of the deceased, this amount must be included in the income of the estate in light of subsections 104(1) and 248(1), under which the heirs of a deceased taxpayer are deemed to be the estate of the deceased for the purposes of the Act. ...

22 June 2004 External T.I. 2004-0060211E5 F - Allocation pour utilisation d'un véhicule à moteur -- summary under Paragraph 6(1)(b)

. … [I]t is unlikely that the clients' places of business would constitute a regular place of work of the representative. ...

17 June 2004 External T.I. 2003-0045411E5 F - Entreprise de placement déterminée -- summary under Paragraph (a)

. … [I]n a situation where the Partnership employs more than 5 full-time employees in its business, the corporation is considered to employ more than 5 full-time employees in that business and thus the corporation meets the exception described in paragraph (a) of the definition of SIB. ...

17 June 2004 External T.I. 2003-0045411E5 F - Entreprise de placement déterminée -- summary under Paragraph 4(1)(a)

. … [I]n a situation where the Partnership employs more than 5 full-time employees in its business, the corporation is considered to employ more than 5 full-time employees in that business and thus the corporation meets the exception described in paragraph (a) of the definition of SIB. ...

29 June 2004 External T.I. 2004-0078951E5 F - Non Arm's Length Sale of Shares, Surplus Stripping -- summary under Subsection 84.1(1)

In the course of making general comments after having indicated that there were insufficient facts, CRA stated: A could be not dealing at arm's length with UNRELATEDCO with respect to A's disposition of the shares of OPCO …. ...

30 July 2004 External T.I. 2004-0063811E5 F - Soutien administratif à une filiale -- summary under Clause 37(8)(a)(ii)(A)

After referring to s. 37(13), CRA stated: [A]dministrative support tasks in respect of the activities of a subsidiary of a taxpayer would not be considered to be SR&ED of the taxpayer because the condition in paragraph 37(13)(b) is not satisfied since the administrative support tasks would not be SR&ED of the subsidiary …. ...

23 September 2004 External T.I. 2004-0088801E5 F - Stop-Loss Provisions -- Grandfathering -- summary under Subsection 112(3.2)

In rejecting this proposition, CRA stated that “it is clear that the preferred shares … were not held by the particular individual on April 26, 1995, notwithstanding that the preferred shares would be deemed to be substituted property for the common shares,” and also noted that a stock dividend did not come within the continuity provisions of s. 131(12) of the amending Bill. ...

14 October 2004 External T.I. 2004-0089921E5 F - Disposition d'une police d'assurance-vie -- summary under Element L

. … [O]ne item that generally reduces the adjusted cost basis [of the policy] is the "net cost of pure insurance", as defined in subsection 308(1) of the Income Tax Regulations, calculated immediately before the end of the calendar year ending in a taxation year commencing after May 31, 1985, in respect of an interest in a life insurance policy (other than an annuity contract) last acquired after December 1, 1982. ...

16 November 2004 External T.I. 2004-0064821E5 F - 88(1) Bump -- summary under Subparagraph 88(1)(c.3)(ii)

. … [S]ubparagraph 88(1)(c.3)(ii) would not apply in such a situation. ...

16 November 2004 External T.I. 2004-0064821E5 F - 88(1) Bump -- summary under Subclause 88(1)(c)(vi)(B)(I)