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14 April 2009 External T.I. 2007-0238221E5 F- Rights of musician-Transfer-- summary under Subsection 56(2) Summary Under Tax Topics- Income Tax Act- Section 56- Subsection 56(2) s. 56(2) not applicable where copyright or royalty interests transferred at FMV As part of a general response respecting the transfer of rights by a musician to a corporation, CRA stated: As illustrated by … IT-335R2 [para. 8] …the sale of a property for consideration less than its fair market value could result in the application of subsection 56(2). ...

8 January 2010 External T.I. 2009-0344061E5 F- Crédit d'impôt pour la rénovation domiciliaire-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 118.04- Subsection 118.04(1)- Eligible Dwelling- Paragraph (a) residence of a partnership, but not a corporation, can be an eligible dwelling CRA indicated that a residence held by a partnership could qualify as an "eligible dwelling" of a partner for home renovation tax credit ("HRTC"), so that it could generate a credit if ordinarily inhabited by the partner (or spouse etc. thereof) who incurred the qualifying expenditures – whereas a shareholder could not claim the credit. ...

25 August 2017 External T.I. 2017-0703351E5- Paragraph 116(5)(a)- reasonable inquiry-- summary under Subsection 116(5.3) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5.3) statutory declaration sufficient if no negative markers When asked whether the reasonable inquiry requirement was met if the purchaser obtains a statutory declaration from the vendor that the vendor is not a non-resident of Canada, and the purchaser has no reason to believe this to be false, CRA indicated that “obtaining such declaration would generally qualify as a reasonable inquiry” – and referred to “a known mailing address outside of Canada or any other indication of the vendor’s residence being outside Canada in the transaction documentation” as examples of circumstances that should put the purchaser on notice. ...

Thus, the fact that an individual has a right of access or legal custody of the child will only be one of the relevant elements to consider …. ...

However, in order to qualify for the medical expense tax credit, it would be necessary to determine whether the only expenses covered by the plan are eligible medical expenses pursuant to subsection 118.2(2) and who is covered by the plan …. ...

2 June 2008 External T.I. 2007-0262511E5 F- Obligation de produire un feuillet T4A-- summary under Subsection 200(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(1) no T4A required by individual in personal capacity paying for professional or home-repair services Regarding its policies as to the requirement to issue T4As for fees paid in excess of $500, CRA stated that it “will not insist on the issuance of a T4A in the situations listed on page 4 of Guide RC4157 … or where “services are rendered to an individual, in a personal capacity, by a professional or any other person engaged in a trade, or where the services are rendered for the repair or maintenance of an individual's principal residence.” ...

20 August 2008 External T.I. 2008-0288561E5 F- Convention de partage d'une société de personnes-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) CRA generally does not challenge sharing agreements based on each partner’s contribution After indicating that an agreement to allocate income to a retired partner generally would be respected but for there being no partnership net income, CRA went on to state: Generally …CRA … does not question the validity of a partnership sharing agreement that is based on the contribution of each partner. ...

11 July 2007 External T.I. 2006-0192101E5 F- Disposition d'actions par un non-résident-- summary under Subsection 212.1(1) Summary Under Tax Topics- Income Tax Act- Section 212.1- Subsection 212.1(1) relief under the 1998 federal budget was not implemented – deemed dividend where NR individual effects pipeline transaction A non-resident individual who had acquired shares of a Canadian real estate company with a low paid-up capital and a high adjusted cost base (stepped up on the death of that individual’s spouse) was deemed to receive a dividend equaling the excess over the shares’ PUC when they were disposed of to another wholly-owned Canadian corporation for a note. ...

22 November 2007 External T.I. 2007-0226001E5 F- Jugement de divorce- Montant forfaitaire-- summary under Paragraph 60(b) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(b) lump sum paid by ex-spouse’s corporation could not be maintenance CRA indicated that an amount payable to a former wife following a divorce judgment likely “could not be maintenance” and likely would not be deductible where the amount was paid by a corporation that previously had employed her and of which her former husband was the sole shareholder, and could be included in her income under s. 15(1) – but more particulars were required to so conclude. ...

After referring to its acceptance of cash damming in IT-533, para. 16, CRA stated: Once the Supreme Court of Canada has rendered its decision in Lipson, we will review the implications of that case and publicly announce the impact of that decision …. ...