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25 June 2002 Internal T.I. 2002-0130177 F- DEBENTURE CONVERTIBLE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Teleglobe applied to find that amount paid by corporation on conversion of convertible debentures was the shares’ stated capital CCRA reviewed the line of cases culminating in Teleglobe, and concluded that the amount paid by the issuer on the conversion of its convertible debentures should be treated as the stated capital of the shares issued, which equaled the face amount of the converted debentures. ...

15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- summary under Paragraph 85(1)(e.2) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(e.2) significant FMV shortfall suggested that a benefit was desired to be conferred Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. ... In finding that s. 85(1)(e.2) likely was applicable unless the TSO chose to respect a price-adjustment clause, the Directorate stated: [I]t is clear that the result of the transaction was that Madame conferred a benefit on Monsieur. … [Furthermore] it seems reasonable … to conclude that Madame desired to confer a benefit on Monsieur since, as sole director of the Corporation, it was she who chose to set the redemption value of the Class D shares at an amount lower than the FMV of the Class A shares transferred in consideration. ...

15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- summary under Subsection 85(7) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(7) amended s. 85(1) election must be filed if price-adjustment clause applied Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. ... After finding that s. 85(1)(e.2) likely was applicable unless a price-adjustment clause was applied, the Directorate indicated to the TSO: … [If] you decide to recognize the price adjustment clause … the taxpayer must file an amended election to give effect to the price adjustment clause. ...

15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date large FMV discrepancy suggested lack of bona fide valuation so that price adjustment clause need not be applied/ if applied, s. 85(1) election must be amended Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. ... The jurisprudence has shown that a price adjustment clause can be ignored in cases where there is no good faith effort to determine the FMV of a property (See: Guilder News ….). On this basis, it seems to us that you would be free to ignore the price adjustment clause and therefore maintain an assessment under 85(1)(e.2). … [If] you decide to recognize the price adjustment clause … the taxpayer must file an amended election to give effect to the price adjustment clause. ...

24 May 2002 Internal T.I. 2002-0130667 F- REGIME PRESTATION EMPLOYES-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amounts “received” under EBP if unrestricted right to receive Under a provision of an employee benefit plan which was assumed, for discussion purposes, to be grandfathered from the salary deferral arrangement rules, an employee could elect at the time of retirement to receive all amounts accumulated in the plan either immediately or in instalments (through the purchase of an annuity). ...

4 October 2002 Internal T.I. 2001-010564A F- PENSION ALIMENTAIRE-ARRERAGES-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt set-off does not constitute payment unless the parties so agree After finding that a lump-sum payment to cover support-payment arrears could be considered as an amount payable on a periodic basis, even though it was less than the amount initially anticipated, the Directorate went on to note: The Court of Appeal judge decided to credit the amount of $XXXXXXXXXX, which consisted of expenses incurred by Monsieur for the benefit of the child, against the balance of the arrears owed to Madame by Monsieur. ...

2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103-- summary under Paragraph 103(4)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) Where a retiring allowance of $30,000 was paid in 30 equal weekly payments of $1,000 to a Quebec employee, the Directorate determined that the rate of withholding would be determined under Reg. 102(1) on the basis of being periodic payments of $1,000 rather than pursuant to Reg. 103(4)(c)(i) as a lump sum payment over $15,000. ...

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. ...

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”). ...