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14 May 2015 CLHIA Roundtable, 2015-0573841C6- 2015 CLHIA Roundtable – Winding-up and ACB CRA Tags 148(7) 88(2) 69(5) Principal Issues: Does subsection 69(5) take precedence over subsection 148(7) in respect of the distribution of an interest in a life insurance policy by a corporation to a shareholder on a subsection 88(2) wind-up of the corporation? ... CLHIA Roundtable-- May 14, 2015 Question 4 Subsection 88(2) Wind-up and Adjusted Cost Basis At the 2005 CALU Roundtable (Technical Interpretation 2005-0116631C6), the CRA indicated that subsection 69(5) would likely take precedence over subsection 148(7) such that on the wind-up of a corporation to which subsection 88(2) applies, a distributed interest in a life insurance policy would be disposed of at fair market value rather than cash surrender value. ... CRA Response: The CRA's position as stated in our response to Question 3(c) at the 2005 CALU Roundtable remains unchanged. ...

Dans le cadre du programme gouvernemental « Québec roule à la puissance verte », l'employeur a reçu une subvention d'environ XXXXXXXXXX $. ... La catégorie 43.1 a été établie en 1994 et prévoit un taux de déduction pour amortissement (« DPA ») accéléré de 30 % selon la méthode de l'amortissement dégressif pour les biens acquis après le 21 février 1994. La catégorie 43.2, qui prévoit un taux de DPA accéléré de 50 %, a été établie en 2005 et vise généralement les biens qui seraient autrement inclus à la catégorie 43.1 mais qui sont acquis après le 22 février 2005 et avant 2020. ...

21 February 2006 External T.I. 2005-0120751E5- Specified Investment Business & Partnerships Unedited CRA Tags 125(7) Principal Issues: Would the exclusion in paragraph 125(7)(b) at the definition of specified investment business be met where the relevant associated corporation was a corporate partner and the partnership provided services to the particular corporation? ... Reasons: Consistent with jurisprudence and our reading of the law. 2005-012075 XXXXXXXXXX Allan Nelson, C.M.A (613) 443-7253 February 21, 2006 Dear XXXXXXXXXX: Re: Definition of "specified investment business"- Technical Opinion Request This is in response to your February 28, 2005, letter and our telephone conversations on September 9, 2005 and January 18, 2006 (XXXXXXXXXX/Nelson), where you asked for our opinion concerning the definition of specified investment business in subsection 125(7) of the Income Tax Act (the "Act"). ...

10 June 2011 Roundtable, 2011-0398371C6- HWTs and Employee Life & Health Trusts Unedited CRA Tags 144.1 Principal Issues: What is the CRA's current position with respect to revising IT-85R2? ... An initial attempt to revise the bulletin was made in 2005 with the release of a draft version of IT-85R3, however, as a result of the issues raised during the public consultation process, we believed that it was necessary to set it aside. ...

8 June 2007 Roundtable, 2007-0240431C6- 2007 STEP Conf-Q. 12-Change in Trustees & Cntrl Unedited CRA Tags 257(7)(a) 256(1) Principal Issues: Can the CRA advise if there have been any further developments on the issue of whether a change in any of the trustees of a trust would result in a change in control of the corporation of which the trust is the shareholder? ... Reasons: On-going issues. 2007 STEP Round Table Q. 12 Change of Trustees and Control In May of 2005, the CRA issued a technical interpretation (2004-0087761E5) that may have widespread implications for corporations that have trusts as shareholders. ...

12 May 2006 External T.I. 2005-0159581E5- "Approved " Status Unedited CRA Tags 37(1)(a)(ii) 37(7) Principal Issues: The client requested that XXXXXXXXXX. be approved as a not-for profit corporation entitled for third party payments for SR&ED. ... Reasons: The determination as to whether a particular entity can be approved can only be made following a review of a particular applicant's submission and related documentation as outlined in Application Policy SR&ED 96-10. 2005-015958 XXXXXXXXXX Charles Rafuse 613-957-8967 May 12, 2006 Dear XXXXXXXXXX: Re: Request for "Approved" Status under Section 37 of the Income Tax Act (the "Act") This is in reply to your letter dated November 9, 2005, requesting that XXXXXXXXXX. be granted approved status for the purpose of subparagraph 37(1)(a)(ii) of the Act. ...

Is the income earned by a farmer under a FIT / microFIT contract considered farming income? ... Would the income earned by a farmer under items 1 & 2 be considered incidental to farming income? ... Acquisitions of such property on or before February 22, 2005 would qualify for inclusion in Class 43.1 by virtue of subparagraph (d)(vi) of that Class. ...

Is the income earned by a farmer under a FIT / microFIT contract considered farming income? ... Would the income earned by a farmer under items 1 & 2 be considered incidental to farming income? ... Acquisitions of such property on or before February 22, 2005 would qualify for inclusion in Class 43.1 by virtue of subparagraph (d)(vi) of that Class. ...

26 May 2010 External T.I. 2009-0342121E5- rooftop solar panels & class 43.2 Principal Issues: 1.will rooftop solar panels & equip qualify for inclusion in class 43.2 under various scenarios subject to the specified energy rules limiting CCA. 2.will claiming cca jeopardize the principal residence exemption? Position: 1.provided expenses incurred for the purpose of producing income & other conditions of the class are met; 2. the principal residence claim will not be jeopardized provided no cca claim is made on the building itself & the earning of income is ancillary to the residence use. ... Acquisitions of such property on or before February 22, 2005 would qualify for inclusion in Class 43.1 by virtue of subparagraph (d)(vi) of that Class. ...