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14 March 2002 External T.I. 2002-0119695 F- Income & Losses/Business or Property-- summary under Agency Summary Under Tax Topics- General Concepts- Agency criteria applied for determining presence of agency Before confirming that ticket sales receipts of the taxpayer may have been generated as agent for charitable organizations, so that they did not generate income to the taxpayer, CCRA stated: In general, the CCRA agrees to recognize a principal-agent relationship between persons for tax purposes provided that: the relationship between the persons concerned is legally one of principal-agent; this implies, among other things, that the transactions relating to the agency are effective and complete from a legal standpoint; this relationship arises from a prior formal agreement and does not constitute an ex post facto arrangement; this relationship does not contravene any legislation; the relationship is not a sham; the relationship is disclosed to the CCRA and the relevant documents are provided to the CCRA at the appropriate time (generally when the relevant tax returns are filed); the facts of the particular situation support the existence of the principal-agent relationship between the persons concerned. ...

4 November 2002 External T.I. 2002-0158885 F- Alloc. of Safe Inc. & Disc. ...

22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1)-- summary under Subsection 15(1) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(1) s. 15(1) ordinarily not applied where a shareholder owes money to a corporation under a genuine or bona fide loan arrangement Discussion of whether s. 15(1) or 56(2) might apply to loans by corporations wholly owned by an individual to a corporation that was partly owned by other persons. ...

18 March 2003 External T.I. 2003-0002915 F- Subsections 40(3.3) & 40(3.4)-- summary under Subsection 40(3.4) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.4) taxpayer can designate order of disposition On December 16, 2002, Holdco sold 200 of its 1,000 common shares of a public corporation to an unaffiliated person $1,500, realizing a capital loss of $500, and less than 10 days after December 16, 2002, Holdco acquired 200 new common shares of the public corporation at a cost of $1,500. ...

8 October 2004 Internal T.I. 2004-0093371I7 F- Crédit d'impôt à l'investissement & impôt minimum-- summary under Subparagraph 127(5)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(5)- Paragraph 127(5)(a)- Subparagraph 127(5)(a)(ii) carryback of ITCs from year where the taxpayer was subject to minimum tax After noting that where minimum tax applies in a particular taxation year (here, 2003), the deductible amount of investment tax credit in respect of property acquired in that year is limited under s. 127(5)(b) to the amount by which the tax otherwise payable under Part I for the year (2003) exceeds the minimum tax applicable to the individual for that year, the Directorate went on to note that the unused investment tax credit balance be carried back to previous years (2000 to 2002) if the investment tax credit amount is higher than this excess: for purposes of the carryback to such prior years, s. 127(5)(a)(ii) takes into account the balance that was not deductible in the particular taxation year (2003). ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C)-- summary under Subsection 91(5) Summary Under Tax Topics- Income Tax Act- Section 91- Subsection 91(5) upward ACB adjustment to the CFA occurring as a result of recognized FAPI under the old s. 94(1) rules represented basis that could be distributed while the trust was subject to the new s. 94(3) trust rules A non-resident discretionary trust (“NRT”) owned all the shares of CFA. Amounts in respect of CFA’s foreign accrual property income had to be included in NRT’s 2002, 2004 and 2006 taxable income by virtue of “old” s. 94(1)(c)(i)(C) (“FAPI-Inclusions”). ...

10 November 2002 Roundtable, 2002-0156845 F- CONGRE 2002 APFF-- summary under Subsection 7(1.1) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.1) realization of s. 7(1.1) gain on shares’ disposition even though they had lost most of their value An employee exercised stock options in 2001 after the CCPC employer became a public corporation and the shares had substantially appreciated – and then sold the shares a year later when they had lost most of their value. CCRA confirmed that the employee realized a taxable benefit in 2002 based on the 2001 value, and realized a capital loss at the same time on the shares’ disposition. ...

In accordance with [Reg.] 4901(1) … a prescribed investment for a registered investment … is a qualified investment for … a registered retirement savings plan ("RRSP"), registered retirement income fund ("RRIF") and deferred profit sharing plan ("DPSP"), respectively. The kinds of property that are qualified investments for an RRSP, RRIF or a DPSP are described in … [ss.] 146(1), 146.3(1) and section 204 … [and Reg.] 4900 …. ... In addition [see] paragraph 21 of … IT-320R3 …. ...

In accordance with [Reg.] 4901(1) … a prescribed investment for a registered investment … is a qualified investment for … a registered retirement savings plan ("RRSP"), registered retirement income fund ("RRIF") and deferred profit sharing plan ("DPSP"), respectively. The kinds of property that are qualified investments for an RRSP, RRIF or a DPSP are described in … [ss.] 146(1), 146.3(1) and section 204 … [and Reg.] 4900 …. ... In addition [see] paragraph 21 of … IT-320R3 …. ...

9 April 2002 Internal T.I. 2001-0112817 F- RESIDENCE PRINCIPALE- VENTE D'UN DUPLEX-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence- Paragraph (e) duplex land allocated between rental and principal residence generally based on the floor areas of the respective building portions Where the owner of a duplex occupied one unit as his principal residence and rented out the other unit, on his sale of the duplex could he treat the entire gain on the land as exempted by the principal residence exemption? ... Our position is supported by … Berkovic … 83 DTC 335 and …. Mitosinka …. ...