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12 May 2016 External T.I. 2014-0552341E5- Subsection 107(4.1)-- summary under Subsection 107(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(2) tainting effect of one 75(2) property CRA confirmed that a personal trust was tainted under s. 107(4.1) when it was settled with a gold coin by one of the capital beneficiaries – so that until the settlor died, none of the other property in the trust could be rolled out under s. 107(2) to the other capital beneficiaries even though such property had been acquired in an arm’s length purchase from an arm’s length vendor. ...

16 March 2012 External T.I. 2012-0432101E5 F- Acquisition d'un séparateur d'huile-- summary under Paragraph 1(q) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 1- Paragraph 1(q) oil separator Class 1 if sufficiently attached to garage Respecting an oil separator acquired by a garage in order to meet government requirements, CRA stated: To the extent that an oil separator is an integral part of a building (sufficiently attached to the building) or can be considered as a component part of a building, we are of the view that the oil separator could be included in the description of Class 1 … [and otherwise] could be included in Class 8. ...

24 November 2011 External T.I. 2011-0416791E5 F- Shareholder Benefit-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) payment by Opco of whole life insurance premiums on policy of which it is beneficiary, but sole shareholder is holder, generates s. 15 benefit – but not policy loan advance Opco is the beneficiary of a universal life insurance policy (the "Policy") on the life of its sole shareholder, Mr. ...

Consequently, in the absence of a sham or express provision in the Act which provides that legal relationships must not be respected, … a lease agreement in civil law is a lease agreement and a sales contract in civil law is a sales contract. ...

17 October 2011 External T.I. 2011-0423361E5 F- Loi sur le courtage immobilier-- summary under Nature of Income Summary Under Tax Topics- Income Tax Act- Section 9- Nature of Income Quebec real estate broker can generate commissions in a controlled corporation After noting that the Quebec Real Estate Brokerage Act (the “REBA”) required a real estate or mortgage broker carrying on brokerage activities through a controlled corporation to treat the remuneration therefor as belonging to the corporation, CRA stated: [I]f the activities of a real estate or mortgage broker under the REBA … can be lawfully exercised through a corporation- which appears to be the case here- remuneration for the activities of the broker will be taxable in the hands of that corporation. ...

After noting that the non-arm’s length nature of these transactions did not preclude access to the s. 110.6(2.1) deduction, CRA stated: … [I]n both of these situations, subparagraph 84.1(2)(a.1)(ii) could apply for the purposes of section 84.1 to reduce the adjusted cost base of the shares acquired by your child. ...

20 April 2010 External T.I. 2010-0355071E5 F- Ligne directrice 4-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 Indian organization did not qualify under Guideline 4 where 20% of clientele lived off reserve CRA indicated that an Indian organization approximately 80% whose clientele were Indians living on reserves would not satisfy the condition in Guideline 4 that the clientele be “exclusively Indians … who for the most part live on reserves,” stating: The term "Indians who...live on reserves" as used in Guideline 4, means that the Indian lives on a reserve in a domestic establishment that is his or her principal place of residence and the centre of his or her daily activities. ...

CRA responded: [W]here a home is not occupied as a principal place of residence … ownership of that residence does not disqualify the individual from the HBTC. ...

14 March 2017 External T.I. 2016-0627311E5 F- Deduction of contribution to an IPP or RCA-- summary under Paragraph 20(1)(q) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(q) non-deductibility if supplementary benefits do not merely proportionately top-up IPP benefits CRA considered a plan that provides supplementary benefits to in individual pension plan to be a salary deferral arrangement rather than a retirement compensation arrangement if the benefits provided for are unreasonable – which CRA will consider to be the case unless the terms of the supplemental plan are substantially the same as those of the IPP and the supplementary benefits merely provide the employee with a supplement for the benefits that would be provided under the IPP but for the defined benefit limit. ...

6 June 2017 External T.I. 2015-0617331E5 F- TFSA- Exempt Contribution-- summary under Paragraph 248(23.1)(a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(23.1)- Paragraph 248(23.1)(a) payment of family-law obligation of deceased to surviving spouse out of deceased's TFSA could qualify The definition of “survivor payment” in s. 207.01(1)- exempt contribution – para. ...