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28 November 2010 Roundtable, 2011-0424761C6- CTF 2010 Q&A #22- ELHTs & HWTs CRA Tags 6(1) 144.1 Principal Issues: Interaction of new ELHT regime with existing HWT regime Position: Both will exist 2010 CTF – November 28, 2010 Employee Life and Health Trusts Question 22 On August 27, 2010, the Department of Finance released revised legislative proposals to accommodate new employee benefit arrangements called employee life and health trusts (ELHTs). ... Notes: (1) Canada, Department of Finance, Legislative Proposals Relating to the Income Tax Act, the Air Travellers Security Charge Act, the Excise Act, 2001 and the Excise Tax Act (Ottawa: Department of Finance, August 2010). (2) Bill C-47 received royal assent on December 15, 2010; SC 2010, c. 25. (3) Interpretation Bulletin IT-85R2, "Health and Welfare Trusts for Employees," July 31, 1986. (4) Income Tax Technical News no. 25, October 30, 2002. ...

Plus particulièrement, vos questions concernent les conclusions que nous avons émises dans le document portant le numéro 2009-0350241E5 (" notre Opinion ") qui traitait de la question de savoir quand un contribuable " est en droit de recevoir " le montant du crédit d'impôt pour investissement relatif au matériel de fabrication et de transformation du Québec (ci après " le Crédit ") aux fins du paragraphe 13(7.1) de la Loi. Ce crédit est prévu à l'article 1029.8.36.166.43 de la Loi sur les impôts du Québec (ci-après " LI "). ... Nos commentaires Tel qu'il est mentionné au paragraphe 22 de la circulaire d'information 70-6R5 du 17 mai 2002, nous avons comme pratique de ne pas émettre d'opinion écrite concernant des transactions projetées autrement que par voie de décisions anticipées. ...

12 July 2013 External T.I. 2011-0415911E5- FA held through partnership-– 95(2)(m) & 95(2)(y) CRA Tags 95(2)(m) 95(2)(y) Principal Issues: For the purposes of applying paragraph 95(2)(a) in determining whether a taxable Canadian corporation that is a member of a partnership has FAPI, does paragraph 95(2)(y) apply to prevent the partnership from having a qualifying interest in a foreign affiliate the shares of which are owned through the partnership? ... XXXXXXXXXX 2011-041591 Yannick Roulier July 12, 2013 Dear XXXXXXXXXX: Re: Foreign affiliate held through a partnership –- paragraphs 95(2)(m) & 95(2)(y) This is further to a letter from XXXXXXXXXX dated July 26, 2011, requesting our comments regarding the application of paragraphs 95(2)(m) and (y) of the Income Tax Act in a situation where a foreign affiliate is held through a partnership. ... Comments Written confirmations of the tax implications inherent in particular transactions are provided by this Directorate where the transactions are proposed and are the subject matter of an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, dated May 17, 2002. ...

Nichols October 15, 2012 Dear XXXXXXXXXX: RE: Ontario FIT / microFIT Programs This is in response to your email of August 3, 2012, wherein you requested clarification of the response to question 8 of the Frequently Asked Questions (“FAQ’S”) relating to the Ontario's FIT / microFit Programs section of the Canada Revenue Agency website. ... Our Comments Written confirmation of the income tax implications inherent in particular transactions is given by this directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request as described in Information Circular 70-6R5 dated May 17, 2002 issued by the Canada Revenue Agency. ... Manager Resources Section Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

10 January 2011 External T.I. 2010-0365421E5- Maternity & Parental Leave for Self Employed Unedited CRA Tags 96(1); 103(1.1); paragraph 2 Partnership Act [RSBC 1996] Principal Issues: How does a general partner show no self-employed income from a [50/50] general partnership during the benefit period under the [new] initiative "Employment Insurance Benefits for Self-Employed People (EIBforSEP)"? ... Written confirmation of the tax implications inherent in particular transactions may only be provided by this Directorate where the transactions are proposed and are the subject matter of an advance income tax ruling submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... Paragraph 2 of the Partnership Act [RSBC 1996] CHAPTER 348 defines Partnership as: "... the relation which subsists between persons carrying on business in common with a view of profit. ...

29 June 2006 External T.I. 2006-0172341E5- Motor Vehicle Allowance & SBI Reimbursement Unedited CRA Tags 6(1)(b)(vii.1) 6(1)(b)(xi) 7306 (ITR) Principal Issues: Whether a reimbursement of an employee's supplementary business insurance (SBI) will render the payment of a motor vehicle allowance unreasonable for the purposes of subparagraph 6(1)(b)(vii.1) of the Act and cause the allowance to be a taxable benefit for the employee recipient. ... Our Comments Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ... Yours truly, Randy Hewlett For Director Business and Partnerships Division Income Tax Rulings Directorate Legislative Policy & Regulatory Affairs Branch ...

17 October 2005 External T.I. 2005-0136781E5- Scholarship, Tuition, & Education Tax Credits Unedited CRA Tags 56(1)(n) 56(3) 118.5(1) 118.6(2) Principal Issues: 1) Can a scholarship exemption be obtained where employment ends, and the employee receives an amount from their employer termed a "retraining allowance", which is paid directly to a school outside Canada for a one-month ESL teacher training course? ... Our Comments: Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5 dated May 17, 2002. ... In certain situations, a taxpayer may be able to claim a tuition tax credit, and / or an education tax credit in respect of taxable employer-paid tuition. ...

16 December 2003 External T.I. 2003-0013335- Qualifying Incomes & Capital Gains Also released under document number 2003-00133350. ... In particular, you have sold some U.S. property, and would like to know if the numerator of the fraction on line 2 entitled "Net foreign non-business income" would include the entire capital gain computed for Canadian income tax purposes, or just the taxable capital gain, which, in 2002, is 50% of the capital gain. ... Yours truly, Olli Laurikainen, C.A., Manager for Director International & Trusts Division Income Tax Rulings Directorate- 2- ...

9 November 2012 External T.I. 2012-0460471E5- T5013 & non-Canadian partnership CRA Tags ITR 805.1 ITR 229(1) ITR 805 Principal Issues: Does a member of a partnership that is not a Canadian partnership have to file a partnership information return (i.e. ... Written confirmation of the tax consequences that apply to a particular fact situation is given by this Directorate only in the context of an advanced income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advanced Income Tax Rulings, dated May 17, 2002. ...

2 June 2005 External T.I. 2005-0116801E5- Airplane Lease Costs & Withholding Tax Unedited CRA Tags 6(1)(a) 15(1) 212(1)(d)(xi) Principal Issues: Canco leases an airplane from USco for use in the shareholder's business travel. 1. ... Our Comments Written confirmation of the tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings, dated May 17, 2002. ...