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29 April 2015 External T.I. 2014-0532691E5 F- Vente – immeuble- syndicat copropriétaire-- summary under Paragraph 149(1)(l) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(l) a syndicate of condominium co-owners could qualify as a s. 149(1)(l) corporation, so that a capital gain realized by it on a condo sale would be exempt A syndicate of co-owners holding condominium units sold one of the condominiums at a capital gain. ...

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves-- summary under Subsection 110.6(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(2) In response to a question "as to whether a taxpayer whose farm property meets the definition as a "qualified farm property" ("QFP") within the meaning of subsection 110.6(1)...will be eligible to claim the capital gains deduction under subsection 110.6(2) on a subsequent disposition of the farm property in circumstances where petroleum or natural gas reserves are discovered on the property," CRA responded: any real property the principal value of which depends on its petroleum, natural gas or related hydrocarbon content will constitute a "Canadian resource property" as defined in subsection 66(15) of the Act by virtue of paragraph (c) of that definition. ...

7 January 2013 External T.I. 2012-0460791E5- Qualified Farm Property & Oil Reserves-- summary under Canadian Resource Property Summary Under Tax Topics- Income Tax Act- Section 66- Subsection 66(15)- Canadian Resource Property In response to a question "as to whether a taxpayer whose farm property meets the definition as a "qualified farm property"... within the meaning of subsection 110.6(1)...will be eligible to claim the capital gains deduction under subsection 110.6(2) on a subsequent disposition of the farm property in circumstances where petroleum or natural gas reserves are discovered on the property," CRA responded: any real property the principal value of which depends on its petroleum, natural gas or related hydrocarbon content will constitute a "Canadian resource property"....For these purposes "principal" means more than 50%. ...

12 March 2015 External T.I. 2014-0541991E5- Objection – Eligible Dividend Designation-- summary under Subsection 89(14.1) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(14.1) designation conditional on appeal result: not acceptable A Canadian-controlled private corporation ("Canco") declared and paid out a dividend at a time it had an insufficient GRIP balance to make an eligible dividend designation. ...

12 April 2016 External T.I. 2015-0595461E5- Australian Super Fund & T1135-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Cost Amount- Paragraph (e) cost amount of pension rights includes future amounts to which legal entitlement An Australian Superannuation Fund (or “Super Fund”) is a government-regulated trust that has been registered and approved by the Australian Government and is funded by contributions from employers and individuals over their working lives in order to provide retirement incomes. ...

12 April 2016 External T.I. 2015-0595461E5- Australian Super Fund & T1135-- summary under Subsection 162(7) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(7) no penalty for reasonably estimating an unknown amount, e.g., the “cost amount” of a pension interest An Australian Superannuation Fund (or “Super Fund”) is a government-regulated trust that has been registered and approved by the Australian Government and is funded by contributions from employers and individuals over their working lives in order to provide retirement incomes. ...

10 May 2012 External T.I. 2012-0440731E5 F- Employer-provided gifts & Awards-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) award of points that could be applied to 40 different services were of near-cash items and, thus, taxable A corporation rewards employees (e.g., for achieving numbers of years of service) by awarding them points that can be applied to purchase 40 different listed services related to work-life-family balance set out in a catalogue, e.g., day care services for school days and spring break; and nutritionist, dietitian, massage therapist, psychologist, financial advisor, and home chef services. ...

21 January 2009 External T.I. 2008-0266191E5 F- Part IV & Capital Gain Strip-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) portion of the dividend received by the recipient corporation that is subject to Pt. ...

10 June 2003 External T.I. 2003-0018915 F- Attribution- Transfers & Loans to Corp.-- summary under Subsection 74.5(6) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(6) s. 74.5(6) applied to an estate-freeze exchange by individual’s Holdco of Opco common shares for preferred shares so that family trust could subscribe for Opco common shares An individual transferred all the common shares of Cco (which, at no point, was a small business corporation) in a s. 85(1) rollover to a Newco (Bco) in consideration for common shares of Bco (being all its common shares). ...

1 February 2005 External T.I. 2004-0083921E5 F- Société mandataire, gain & CIÉ-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax US taxes paid by a corporation based on falsely representing that the related gain was its gain could generate a FTC to the Canadian shareholder for which it in fact was agent A corporation acquired a building in the US as agent for its individual shareholder pursuant to a nominee agreement. ...