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31 July 2002 Internal T.I. 2002-0143137- EXPENSES & BENEFITS YACHTS Unedited CRA Tags 18(1)(1) 1102(1)(F) 15(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... July 31, 2002 Mr. Leonard Fornelli HEADQUARTERS Verification and Enforcement Division Randy Hewlett, B.Comm. Ottawa Tax Services Office 613-957-8973 2002-014313 Deductible Expenses and Shareholder Benefits- Yachts We are writing in response to your inquiry of May 29, 2002, regarding the above-noted issue. ...

5 July 2002 Internal T.I. 2002-0144257- 20(12) Deduction & Accrual Basis Income Unedited CRA Tags 126 (1) 126 (7) 20 (12) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... July 5, 2002 Ms. Sheila Barnard Eliza Erskine Individual Returns and Payments 952-1361 Processing Directorate 25 McArthur Road, 8th Floor, Tower C 2002-014425 Interaction Between the Foreign Tax Credit ("FTC") Calculated Under Subsection 126(1) of the Income Tax Act (the "Act") and the Deduction Available Under Subsection 20(12) of the Act (the "20(12) Deduction"), Where the Foreign-Source Income is Taxed in Canada on an Accrual Basis and Taxed in the Foreign Country on a Cash Basis We are writing in response to your email letters to us of May 27, 2002 (the "May Email Letter"), and June 6, 2002 (the "June Email Letter"), regarding the above-noted subject. We also acknowledge our telephone conversation with you of June 19, 2002 (Wilson/Barnard). ...

22 February 2002 Internal T.I. 2001-0101867- Shareholder- Loans & 15(1) Unedited CRA Tags 15(1) 56(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... February 22, 2002 XXXXXXXXXX HEADQUARTERS XXXXXXXXXX Tax Services Office Reorganizations and Tax Avoidance Section Resources Division Michael Cooke (613) 957-2126 2001-010186 XXXXXXXXXX We are writing in response to your memorandum dated September 14, 2001, wherein you requested our views concerning the application of subsections 15(1) and 56(2) of the Income Tax Act (the "Act") where a corporation advances funds to another corporation at the direction of the controlling shareholder. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election CRA Tags ITR 5901(2.2) S.79 of Bill C-48 ITR 5901(2.1) ITR 5901(2)(b) 95(1) foreign accrual property income Principal Issues: 1) Do the surplus pools of a given CFA have to be adjusted as a result of a FACL carryback against the TCG portion of the FAPI inclusion reported in a previous year? ... The relevant part of paragraph 79(2)(a) of Bill C-48 reads as follows, as modified to incorporate the relevant deadlines that would be applicable in the context of the facts submitted (see text underlined): (…) if the corporation (…) elect in writing under this paragraph in respect of all of their respective foreign affiliates and file the election with the Minister of National Revenue on or before the day that is the later of (…) the filing-due dates for their taxation years that include the day on which this Act receives royal assent [June 30, 2014] and the day that is one year after the day on which this Act receives royal assent [June 26, 2014], subsections 5901(2) to (2.2) of the Regulations, as enacted by subsection (1), apply to dividends paid after December 20, 2002 by all the respective foreign affiliates of the elector corporations (…) In the context of the present case, the election for the PAS election rules to apply to the 2010-Dividend would have to have been made on or before June 30, 2014. ... Furthermore, the election to make the PAS election rules applicable to dividends paid after December 20, 2002 does not alleviate the taxpayer's responsibility to file the PAS election itself. ...

8 November 2022 Internal T.I. 2022-0942701I7- RCMP cadet training – service buyback Unedited CRA Tags 5, 6, 147.1(11), 8501(2), 8503(3)(a)(i) Principal Issues: In the circumstances, is the period of cadet training completed by an RCMP cadet eligible service for purposes of subparagraph 8503(3)(a)(i) of the Regulations? ... November 8, 2022 HEADQUARTERS HEADQUARTERS Registered Plans Directorate Income Tax Rulings Directorate Irina Schnitzer Attention: Jeff Boxer 2022-094270 Re: Royal Canadian Mounted Police (“RCMP”) Cadet Training – Eligible Service We are writing in response to your email dated July 5, 2022, wherein you requested our views on whether the period of cadet training completed by an RCMP cadet constitutes eligible service for purposes of subparagraph 8503(3)(a)(i) of the Income Tax Regulations (the “Regulations”). ... (footnote 1) In addition, in Dhillon v The Queen, 2002 DTC 2083 (“ Dhillon ”) the Tax Court of Canada concluded that in the circumstances presented at trial there was an employee/employer relationship between the RCMP cadet and the RCMP during the period of cadet training. ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C) CRA Tags 94(3) Principal Issues: Can a non-resident trust that is subject to "new" subsection 94(3) deduct an amount under subsection 91(5) in respect of a FAPI inclusion resulting from the application of "old" clause 94(1)(c)(i)(C)? ... 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” clause 94(1)(c)(i)(C) (“FAPI-Inclusions”). ... Issue We’ve been asked for our views on whether a subsection 91(5) deduction would be available to NRT in respect of the dividend received from CFA in its final taxation year, in order to take into account the FAPI-Inclusions resulting from the application of “old” clause 94(1)(c)(i)(C) in 2002, 2004 and 2006. ...

24 April 2003 Internal T.I. 2002-0169537- SR & ED- ACQUIRING RIGHTS Also released under document number 2002-01695370. ... The October 16, 2002 memorandum described a scenario whereby a software developer builds onto an existing base using a development platform (the "Platform") to create a new software product. ... Canco 1 has represented that the Software was used as a tool to assist in the development of its technology / product, and that the Software could not directly achieve the goals initially set out and was rendered virtually useless. ...

Your enquiry concerns the policy stated in Income Tax Technical News # 29 ("ITTN 29") and in particular, its application to the BC ITC. ... Therefore, in your opinion, the BC ITC would be included in income for the taxation year ended December 31, 2002 notwithstanding that the amount is deemed to be applied in a subsequent year. ... In either case, the amount would not be considered received in 2002. It would likely be considered received in the 2003 taxation year, and would therefore be reported in that year. ...

Le montant de ce choix aurait excédé le montant du CDC de XCO à ce moment d'environ XXXXXXXXXX $. ... Au cours de l'année 2002, YCO aurait fait un choix de verser un dividende en capital à ses actionnaires d'un certain montant en vertu du paragraphe 83(2). Les calculs visant à supporter le montant du CDC disponible en 2002 feraient état du versement d'un dividende en capital d'environ XXXXXXXXXX $ effectué en 1997. b) Nous comprenons qu'à votre connaissance, l'ARC n'aurait jamais reçu le choix de dividende en capital présumément effectué par YCO en 1997 (ci-après le "Choix de 1997"). ...

23 January 2003 Internal T.I. 2003-0183797- Capital Div Account- MFC & MFT Distrib. ... Brooks Industry Specialist Trusts Section Financial Services Quebec Tax Services 165 de la Pointe aux Lièvres Street South Québec QC G1K 7L3 2003-018379 Capital Dividend Account We are replying to your query of September 9, 2002, in which you commented on our technical interpretation E 2000-0036585. ...