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25 April 2022- 11:21pm We have translated 10 more CRA severed letters Email this Content We have published 2 translations of CRA severed letters released last week and a further 8 translations of CRA interpretation released in February and January of 2005. ... These are additions to our set of 2,014 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 17 ¼ years of releases of such items by the Directorate. ... ROC distribution) irrespective whether effected as cash or unit distribution Income Tax Act- Section 248- Subsection 248(25.3) cost under s. 248(25.3) for distribution of ordinary income or capital gain made as units distribution 19 January 2005 External T.I. 2004-0081001E5 F- Réserve de valorisation d'une coopérative Income Tax Act- Section 135- Subsection 135(4)- Allocation in Proportion to Patronage question of fact whether distributions of enhancement reserves are allocations in accordance with patronage Income Tax Act- Section 181.2- Subsection 181.2(3)- Paragraph 181.2(3)(b) enhancement reserve of Quebec cooperative added to capital 6 January 2005 External T.I. 2004-0087221E5 F- Modification de la déclaration d'une société Income Tax Act- Section 53- Subsection 53(2)- Paragraph 53(2)(h)- Subparagraph 53(2)(h)(i.1) return amendment should be requested where a capital gain has been unreported due to a missed ROC distribution 24 January 2005 External T.I. 2004-0099471E5 F- Convention de retraite pour un actionnaire-employé Income Tax Act- Section 67 81 Roundtable position on shareholder-manager compensation also applies to RCA contributions Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(r) no deduction regarding pre-incorporation services, and longstanding CRA position re shareholder-manager compensation Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(x) Part XI.3 tax and s. 56(1)(x) income inclusion apply even where RCA contribution is partially or fully non-deductible Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement a significant reduction in bonus or salary matched by an RCA contribution likely suggests it instead is an SDA 20 January 2005 External T.I. 2004-0104921E5 F- RPDB et déficit cumulé Income Tax Act- Section 147- Subsection 147(1)- Profit Sharing Plan corporation with an accumulated deficit is not precluded from registering a DPSP ...

8 May 2019- 11:45pm Owen J finds that it was costly for Justice to pursue its allegations of sham in the Cameco transfer-pricing litigation Email this Content Owen J made a lump sum award for legal fees of Osler borne by Cameco in its successful appeal of transfer-pricing adjustments for three of the years in dispute (2003, 2005 and 2006) of $10.25M, which represented about 35% of the Osler fees charged for those years. Factors mentioned by Owen J included: Settlement offers made by Cameco (one less than 30 days before trial, and one after trial) did not have any real bearing on his award given their “ de minimis nature” (i.e., although Cameo offered “$32 million of additional taxable earnings in 2006 … no additional tax in any of the three years under appeal” was offered. ...

These are additions to our set of 1,734 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 14 ¾ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2006-12-01 11 December 1995 Internal T.I. 95056370- Traitement fiscal- versement particulier- indien Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(u) benefits paid to Cree hunters regarding their hunting and trapping activities were s. 56(1)(u) support payments that were not exempted under s. 87 Other Legislation/Constitution- Federal- Indian Act- Section 87 benefits paid to Crees to support their traditional hunter lifestyle were social assistance 2006-11-17 8 November 2006 External T.I. 2006-0176171E5 F- Revente d'un bien amortissable- alinéa 13(7)e) Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(b)- Subparagraph 39(1)(b)(i) capital loss denied on sale of building – proceeds reflected in UCC reduction Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- F application of disposition expenses under Element F Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(e) no deemed CCA class for s. 13(7)(e) denial 7 November 2006 External T.I. 2006-0201261E5 F- REER: Legs à une fiducie exclusive au conjoint Income Tax Act- Section 146- Subsection 146(8.1) surviving spouse would be "beneficially interested" in the estate of a deceased RRSP annuitant by virtue of being a beneficiary of a testamentary trust 14 November 2006 External T.I. 2006-0201371E5 F- FERR: Legs à une fiducie exclusive au conjoint Income Tax Act- Section 146.3- Subsection 146.3(1)- Designated Benefit- Paragraph (a) amount funded with capital encroachment out of spousal trust equaling RRIF of testator would be eligible for the election 16 November 2006 External T.I. 2006-0204901E5 F- Meaning of Full Voting Rights Income Tax Act- Section 186- Subsection 186(2) requirement for special meeting of preferred shareholders to approve an adverse amendment to articles does not detract from full voting rights of common shareholders 8 November 2006 External T.I. 2006-0208601E5 F- Crédit d'impôt pour transport en commun Income Tax Act- Section 118.02- Subsection 118.02(1)- Public Commuter Transit Services definition extends to ferrying of motorists 15 November 2006 External T.I. 2004-0083461E5 F- Feb. 2004 Proposals- Paragraph 85(1)(d.11) Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(d.11) application date of s. 85(1)(d.11) 7 October 2005 Roundtable, 2005-0140891C6 F- Disposition d'une immobilisation Income Tax Act- Section 14- Subsection 14(1)- Paragraph 14(1)(b) illustration of application of formula where the vendor of goodwill previously acquired it in a NAL transfer at a gain to the transferor 7 October 2005 Roundtable, 2005-0141021C6 F- Actions admissibles de petite entreprise Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation if Opco and Realtyco are held equally by two unrelated individuals, Realtyco is not an SBC if it holds more than 50% of its assets as debt of Opco 10 November 2006 External T.I. 2006-0174681E5 F- Salaire versé par un employé à un adjoint Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(i)- Subparagraph 8(1)(i)(ii) position in IT-352R2, para. 1 consistent with Longtin ...

These are additions to our set of 1,859 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 15 ¾ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2006-02-10 2 February 2006 Internal T.I. 2005-0129131I7 F- Assessing 163(2) penalty Income Tax Act- Section 163- Subsection 163(2) s. 163(2) can be imposed where false adjustments are requested, without the necessity to first process those adjustments 2006-02-03 31 January 2006 External T.I. 2005-0151041E5 F- Régimes de sécurité sociale étrangers Treaties- Income Tax Conventions- Article 29 plan recognized as a pension plan under Art. 29(5) of the Cda-France Convention cannot be an EBP 27 January 2006 External T.I. 2005-0164611E5 F- Société immobilière de pension- sens de location Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(ii)- Clause 149(1)(o.2)(ii)(A) providing meals, medical services and housekeeping in a seniors apartment would put the corp. offside 31 January 2006 External T.I. 2006-0167501E5 F- Retenues à la source Income Tax Regulations- Regulation 100- Subsection 100(3)- Paragraph 100(3)(c) reasonable belief can be based on confirmation from annuitant 2006-01-27 4 January 2006 Internal T.I. 2005-0115801I7 F- Convention de retraite Income Tax Act- Section 67 Petro-Canada applied re determining reasonableness Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement contributions to a purported RCA that contemplated excessive benefits also were not in relation to an SDA because the contributions were instead were indirect shareholder appropriations Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement arrangement was not an RCA because the benefits were not reasonable Income Tax Act- Section 56- Subsection 56(2) contributions to purported RCA that provided excessive benefits to employee/ultimate shareholders were included in the direct shareholders’ income under s. 56(2) Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(r) excessive benefits would have resulted in denial under ss. 18(1)(o.2) and 20(1)(r) had the arrangement qualified as an RCA 19 January 2006 External T.I. 2006-0165471E5 F- Fiducie exemptée d'impôt Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(z.1) exemption of trust for closure costs of Quebec disposal facility 2006-01-20 21 December 2005 External T.I. 2005-0150711E5 F- Wind turbines- Class 43.1 Income Tax Regulations- Schedules- Schedule II- Class 43.1- Paragraph (d)- Subparagraph (d)(v) lessor of lands can renounce rights of accession so that operator can own the wind turbines 2006-01-13 6 January 2006 External T.I. 2005-0159421E5 F- Dons visant un programme particulier Income Tax Act- Section 248- Subsection 248(30) acceptable to direct that donation to school where donor’s grandson is student can direct that the funds be used to purchase texts 2006-01-06 22 December 2005 External T.I. 2005-0151091E5 F- Allocation de retraite- retenue à la source Income Tax Regulations- Regulation 100- Subsection 100(3)- Paragraph 100(3)(c) confirmation of RRSP deduction limit is not required from the employee for the portion of the retiring allowance that is eligible for deduction under paragraph 60(j.1) 22 December 2005 External T.I. 2005-0162001E5 F- Déductibilité police d'assurance-vie Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.2) no assignment as required for premium deductibility by the taxpayer where the bank starts out as the policy owner ...

9 March 2021- 10:36pm It is queried whether Canadian taxpayers are owners of securities held by them through intermediaries in accordance with the Securities Transfer Acts Email this Content Since 2005, a security entitlement system (pursuant to Sec urities Transfer Act s) has been adopted by all the provinces. ... Tax Topics (Wolters Kluwer), No. 2556, 2 March 2021, p. 1 under General Concepts – Ownership. ...

These are additions to our set of 1,744 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 14 ¾ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2006-11-17 7 October 2005 Roundtable, 2005-0141151C6 F- Lotissement de biens Income Tax Act- Section 248- Subsection 248(21) s. 248(21) can apply to partitioning a building into separately-owned units 12 September 2006 Internal T.I. 2005-0147801I7 F- Déduction pour frais judiciaires d'un employé Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(b) legal fees incurred in defending against allegations of harassment were non-deductible 24 October 2006 Internal T.I. 2006-0203901I7 F- Avantage automobile Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) bus stop near the employee’s home does not qualify as a pick-up point regarding the exception for employer-assisted commuting 2006-11-10 26 October 2006 External T.I. 2006-0170341E5 F- Subsections 87(2.1) and 87(2.11) Income Tax Act- Section 87- Subsection 87(2.1) s. 87(2.11) does not affect the aging of previously-incurred losses and is relevant to carry-backs by the Amalco Income Tax Act- Section 87- Subsection 87(2.11) purposes of s. 87(2.11) is to allow parent to use losses realized by the new corporation (so as to carry back) 27 October 2006 External T.I. 2005-0157321E5 F- Winding-up of a wholly-owned corporation Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c)- Subparagraph 88(1)(c)(ii) character of property usually regarded as retained in the hands of the parent Income Tax Act- Section 9- Capital Gain vs. ... Profit- Loans/receivables the sale of receivables that were generated on income account is on income account 2006-10-27 3 October 2006 External T.I. 2006-0204181E5 F- Déduction de frais de thérapie Income Tax Act- Section 118.4- Subsection 118.4(1)- Paragraph 118.4(1)(c) scope of activities of daily living 2006-10-20 28 September 2006 External T.I. 2006-0197841E5 F- Shareholders agreement & 256(1.4) Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b)- Subparagraph 251(5)(b)(i) technically a contingent right to acquire control where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares Income Tax Act- Section 256- Subsection 256(1.4)- Paragraph 256(1.4)(a) s. 256(1.4) technically applies where each 25% shareholder has an obligation to acquire shares of another shareholder offering its shares ...

These are additions to our set of 1,591 full-text translations of French-language severed letters (mostly, Roundtable items and Technical Interpretations) of the Income Tax Rulings Directorate, which covers all of the last 13 ½ years of releases of Interpretations by the Directorate. ... (a)(i)(A) can be bad income for purposes of the substantially all test 17 February 2021 External T.I. 2018-0768051E5 F- Contrat de crédit-bail Income Tax Act- Section 49- Subsection 49(3) a portion of the lease payments under a lease with a bargain purchase option recharacterized as consideration for the option Income Tax Act- Section 13- Subsection 13(5.2) acquisition of leased vehicle pursuant to bargain purchase option followed by sale of vehicle could engage s. 13(5.2) Income Tax Act- Section 16.1- Subsection 16.1(1) truck tractor is prescribed property General Concepts- Substance lease payments, but not the lease itself, could be recharacterized Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(ii) leasing contract cannot be recharacterized as a secured loan funding an acquisition of depreciable property Income Tax Act- Section 68 lease payments for vehicle lease with bargain purchase option are allocated between ACB of option and deductible lease payments 5 March 2021 External T.I. 2017-0713041E5 F- Allocation pour usage d’un véhicule à moteur Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(x) it can be acceptable to cap the kilometres for which a car allowance is paid Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) unreasonably low allowance may be taxable 2008-02-01 23 January 2008 External T.I. 2007-0237251E5 F- Résidence principale- Destruction d'un triplex Income Tax Act- Section 54- Principal Residence- Paragraph (e) garage remaining after destruction of triplex by fire was part of the contiguous land Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(b) gain on triplex destroyed by fire then sold should be allocated between the personal use portion and rental portion based on relative building areas, but with years of use being pre-fire 23 January 2008 Internal T.I. 2007-0255351I7 F- Frais médicaux- déplacement Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(g)- Subparagraph 118.2(2)(g)(iii) certificate should state why the physician considers that there are no adequate and appropriate medical services in the venue where the patient resides 2008-01-18 7 January 2008 External T.I. 2007-0225481E5 F- GRIP Addition for 2006 Income Tax Act- Section 89- Subsection 89(7) GRIP addition from subsidiary resulting from 2001 and 2005 dividends 11 January 2008 External T.I. 2007-0227061E5 F- Revenu imposable sociétés associées non-résidentes Income Tax Act- Section 127- Subsection 127(10.2) taxable income of non-resident associated corporations, which are not taxable in Canada under s. 2(3), is ignored 7 January 2008 External T.I. 2007-0227071E5 F- GRIP Addition for 2006 Income Tax Act- Section 89- Subsection 89(7) GRIP addition from subsidiary equaling its GRIP given dividends paid by it in excess of that amount 10 January 2008 External T.I. 2007-0227191E5 F- REVENUS D'UNE SOCIÉTÉ DE PERS.- PART PRIVILÉGIÉE Income Tax Act- 101-110- Section 103- Subsection 103(1) common and preferred units can be used as a mechanism for profits to be allocated to each partner’s interest (a single property) Income Tax Act- Section 53- Subsection 53(1)- Paragraph 53(1)(e)- Subparagraph 53(1)(e)(i) division of partnership interest into preferred and common units does not affect determination of partnership interest’s ACB 18 January 2008 External T.I. 2007-0235131E5 F- Faux frais de déplacement Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii) Treasury Board allowance rates generally are reasonable, even when applied to entertainment 10 January 2008 Internal T.I. 2007-0254551I7 F- Provision relative à certaines marchandises Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m)- Subparagraph 20(1)(m)(i) ss. 12(1)(a)(i) inclusion and 20(1)(m)(i) available for gift certificates sold to franchisees where goods are only tendered to franchisee, with adjustment for unredeemed certificates Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m.2) s. 20(1)(m.2) available for returned gift certificates sold to franchisees 10 January 2008 External T.I. 2005-0139681E5 F- Dépenses reportées à une année ultérieure Income Tax Act- Section 9- Timing expense generally is deductible when incurred if it generates both current and future benefits 2007-11-30 14 November 2007 Internal T.I. 2007-0254601I7 F- Paiement incitatif- Bon de souscription Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iii) value of share purchase warrant granted to asset vendor as an inducement to agree to a longer term services agreement with purchaser was includible under s. 12(1)(x) Income Tax Act- Section 52- Subsection 52(1) value of share purchase warrant included in recipient’s income under s. 12(1)(x) increased ACB of warrant ...