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Current CRA website
T4RIF, Statement of Income From a Registered Retirement Income Fund
<sps_cntrb_ind></sps_cntrb_ind> Contributor spouse or common-law partner indicator- Required 1 numeric- T4RIF slip, box 26- indicate whether the annuitant’s spouse or common law partner has ever contributed to the retirement income plan- if spouse or common law partner has never contributed or if you are single, code as 1- if spouse or common law partner has contributed to this plan, code as 2 <sps_sin></sps_sin> Contributor spouse or common-law partner social insurance number (SIN)- Required if spouse or common–law partner contribution indicator is 2- 9 numeric- T4RIF slip box 32 Enter zeroes in the entire field if:- spouse or common-law partner contribution indicator is 1,- spouse or common–law partner SIN is not available,- you are single <rpt_tcd></rpt_tcd> Report Type Code- Required 1 alpha- originals = O- amendments = A- cancel = C Note: An amended return cannot contain an original slip. ... <dy></dy> Day of Death- 2 numeric- T4RIF box 30- day of the month that the recipient died (e.g. 04,31) <mo></mo> Month of Death- 2 numeric- T4RIF box 30- month that the recipient died (e.g. 03,12) <yr></yr> Year of Death- 4 numeric- T4RIF box 30- year that the recipient died (e.g. 2005) </DTH_DT> <T4RIF_AMT>- all of the amounts are 9 numeric- enter dollars and cents <tx_amt></tx_amt> Taxable Amounts- T4RIF slip, box 16 <deem_dces_amt></deem_dces_amt> Deemed receipt by annuitant on death- T4RIF slip, box 18 <deem_drgst_amt></deem_drgst_amt> Deemed receipt by annuitant on deregistration- T4RIF slip, box 20 <oth_inc_dedn_amt></oth_inc_dedn_amt> Other Income or Deductions- T4RIF slip, box 22- if negative amounts are being reported, include the "–"indicator before the dollar amount <excs_amt></excs_amt> Excess amounts- T4RIF slip, box 24 <tx_ddct_amt></tx_ddct_amt> Tax deducted- T4RIF slip, box 28 <tx_pay_amt></tx_pay_amt> Tax-paid amount- T4RIF slip, box 36 <mrrg_bkdn_tramt></mrrg_bkdn_tramt> Transfers on marriage or common-law relationship breakdown- T4RIF slip, box 35- amount directly transferred under a decree, order, or judgment of a court or under a written agreement relating to a division of a property between the individual’s current or former spouse or common-law partner in settlement of rights arising from the breakdown of the relationship <rrif_alda_amt></rrif_alda_amt> Advanced life deferred annuity purchase- T4RIF slip, box 37- 13 character (allows for negatives, dollar and cents) <t4rif_cye_fmv_amt></ t4rif_cye_fmv_amt> Year end FMV – Fair market value- Required, 11 numeric- T4RIF slip, box 38- Enter "0.00" if there is no FMV value to report Note: Required for tax years 2023 and subsequent </T4RIF_AMT> </T4RIFSlip> <T4RIFSummary> <bn></bn> Business Number (BN)- Required, 15 alphanumeric, 9 digits RP 4 digits, example 000000000RP0000- enter the account number as used on Form PD7A, Statement of Account for Current Source Deductions Note: To process a return, the complete BN is Required. ... <cntc_area_cd></cntc_area_cd> Contact area code- Required, 3 numeric- area code of telephone number <cntc_phn_nbr></cntc_phn_nbr> Contact telephone number- Required, 3 numeric with a (-), followed by 4 numeric- telephone number of contact <cntc_extn_nbr></cntc_extn_nbr> Contact extension- 5 numeric- extension number of the contact </CNTC> <tx_yr></tx_yr> Taxation year- Required, 4 numeric- taxation year (e.g., 2002) <slp_cnt></slp_cnt> Total number of T4RIF slip records- Required, 7 numeric- total number of T4RIF slip records filed with this T4RIF Summary <rpt_tcd></rpt_tcd> Report Type Code- Required, 1 alpha- originals = O- amendments = A Note: An amended return cannot contain an original slip. ...
Current CRA website
EDBN6 Excise Duty Rate Changes on Beer Produced by Small and Mid-Sized Brewers
If a brewer produced less than 300,000 hectolitres in 2005 and produces over 300,000 hectolitres in 2006, they must pay the full rate of duty for all the beer produced in 2006, including the first 300,000 hectolitres. 2. If a brewer produced less than 300,000 hectolitres of beer in 2005 and forecasts production for 2006 to be less than 300,000 hectolitres, the brewer may pay at the reduced rates of duty. ...
Current CRA website
Other items of interest
Benefit programs and benefit-related services delivered by the Canada Revenue Agency Seven federal benefit programs Canada child tax benefit Disability tax credit Goods and services tax/harmonized sales tax credit Children’s special allowances Universal child care benefit – on behalf of Employment and Social Development Canada Working income tax benefit advance payments Canada child benefit Thirty-three ongoing benefit programs for provinces and territories British Columbia – BC family bonus (1996) Alberta family employment tax credit (1997) New Brunswick child tax benefit (1997) New Brunswick working income supplement (1997) Newfoundland and Labrador harmonized sales tax credit (1997) British Columbia – BC earned income benefit (1998) Saskatchewan child benefit (1998) Northwest Territories child benefit (1998) Northwest Territories – territorial worker’s supplement (1998) Nova Scotia child benefit (1998) Yukon child benefit (1999) Nunavut child benefit (1999) Nunavut – territorial worker’s supplement (1999) Newfoundland and Labrador child benefit (1999) Newfoundland and Labrador seniors’ benefit (1999) Saskatchewan low-income tax credit (2000) Newfoundland and Labrador – mother baby nutrition supplement (2001) Ontario child benefit (2007) British Columbia low-income climate action tax credit (2008) Ontario senior homeowners’ property tax grant (2009) Ontario sales tax credit (2010) British Columbia harmonized sales tax credit (2010) Nova Scotia affordable living tax credit (2010) Ontario energy and property tax credit (2011) Northern Ontario energy credit (2011) Ontario trillium benefit (2012) New Brunswick school supplement (2012) Prince Edward Island sales tax and credit (2013) British Columbia early childhood tax benefit (2015) Alberta child benefit (2016) New Brunswick harmonized sales tax credit (2016) Newfoundland and Labrador income supplement (2016) Alberta climate leadership adjustment rebate (2017) Ten one-time payment programs Relief for heating expenses (federal) (2000) British Columbia – BC energy rebate (2001) Alberta energy tax refund (2001) Ontario taxpayer dividend (2001) Nova Scotia taxpayer refund (2003) Alberta 2005 resource rebate (2005) Energy cost benefit (federal) (2005) Ontario home electricity relief (2006) British Columbia climate action dividend (2008) Ontario sales tax transition benefit (2010) One hundred and seven data exchange and data transfer services Seventy income verification data exchanges using File Transfer Protocol with provinces and territories to support programs Four income verification data exchanges using Managed Secure File Transfer with federal supports programs Eight data transfers with provinces to support top-ups for CRA administered child benefit programs Six data exchanges and transfers to support the Nova Scotia pharmacare program, the British Columbia low-income climate action tax credit/BC harmonized sales tax credit, Ontario senior homeowners property tax grant, Ontario trillium benefit, Prince Edward Island sales tax credit and to assist the ministère du Revenu du Québec in administering the Quebec Taxation Act Seven national child benefit supplement data exchanges with provinces and territories to facilitate the calculation of social assistance One data transfers of income and child information to support administration of the Quebec family allowance programs Eleven data exchanges and data transfers to support federal administration of the employment insurance family supplement, guaranteed income supplement, Canada learning bond, Canada education savings grant (basic grant and additional grant), Canada disability savings bond, Canada disability savings grant, Old Age Security recovery tax, universal child care benefit, employment insurance long tenured workers program and Old Age Security Proactive Enrolment. ...
Current CRA website
Actuarial Bulletin No. 1R1
The individual became a member of the plan on January 1, 2005, turned 65 years old on January 1, 2013, and has decided to delay his retirement. ... Plan provisions Plan Provisions Plan effective date: January 1, 1991 Benefit formula: Minimum of 1.5% of final average earnings over 3 years (FAE3), or the maximum pension limit times the years of credited service Normal retirement age: 65 Normal form of pension: Life only Post-retirement indexing: Fully indexed to the consumer price index (CPI) Provision of DB limit projection: Yes Actuarial equivalence for delayed retirement: Yes Employee data Employee Data Shareholder (Y/N): No (non-connected person) Sex: Male Date of birth: January 1, 1948 Date of hire: January 1, 2005 Attained age: 67 Pensionable service: 10 years Employee Earning Data Year Earnings FAE3 (at January 1) 2005- 2012 $50,000 2013 $55,000 $50,000 2014 $60,000 $51,667 2015 (expected) $62,400* $55,000 2016 (expected) $64,896* $59,133 2017 (expected) $67,492* $62,432 2018 $64,929 *based on assumed salary increase rate Actuarial assumptions Actuarial assumptions Valuation date: January 1, 2015 Valuation rate (before retirement): i = 6% Salary increase: s = 4% Inflation rate (that is CPI): 2.50% Indexation of pension: CPI % Valuation rate (after retirement): i ' = 3.41% (1.06/1.025 – 1) DB limit projection rate: 3% per year Mortality table: CPM2014 with mortality improvement scale CPM-B (post-retirement only) Retirement date: January 1, 2018 Retirement age: 70 Funding method: Projected Accrued Benefit Payment mode of retirement benefits: Monthly, in advance Mode of payment of normal cost (NC): Lump sum at the beginning of the year Review Review B 65 payable as of January 1, 2013 = 1.5 % * $ 50,000 * 8 = $ 6,000 b 66 65 ≤ S v c < 66 payable as of January 1, 2014 = 1.5 % * $ 51,667 * 1 = $ 775 b 67 66 ≤ S v c < 67 payable as of January 1, 2015 = 1.5 % * $ 55,000 * 1 = $ 825 b 68 67 ≤ S v c < 68 payable as of January 1, 2016 = 1.5 % * $ 59,133 * 1 = $ 887 b 69 68 ≤ S v c < 69 payable as of January 1, 2017 = 1.5 % * $ 62,432 * 1 = $ 936 b 70 69 ≤ S v c < 70 payable as of January 1, 2018 = 1.5 % * $ 64,929 * 1 = $ 974 b 70 payable as of January 1, 2018 = 1.5 % * $ 64,929 * 1 = $ 974 B 70 S v c < 65 = 1.5 % * $ 64,929 * 8 = $ 7,791 The actuarial liability (AL) as at the valuation date is determined as follows: A L @ 1 / 1 / 2015 = $ 7,791 + max 0; $ 6,000 * 1 + i 70- 65 p 65 5 * a ¨ 65 @ i ' 12 a ¨ 70 @ i ' 12- $ 7,791 + $ 974 + max 0; $ 775 * 1 + i 70- 65.5 p 65.5 4.5 * a ¨ 65.5 @ i ' 12 a ¨ 70 @ i ' 12- $ 974 + $ 974 + max 0; $ 825 * 1 + i 70- 66.5 p 66.5 3.5 * a ¨ 66.5 @ i ' 12 a ¨ 70 @ i ' 12- $ 974 * a ¨ 70 @ i ' 12 * v i 70- 67 This can be simplified to: A L @ 1 / 1 / 2015 = max $ 7,791; $ 6,000 * 1 + i 70- 65 p 5 65 * a ¨ 65 @ i ' 12 a ¨ 70 @ i ' 12 + max $ 974; $ 775 * (1 + i) 70- 65.5 p 4.5 65.5 * a ¨ 65.5 @ i ' 12 a ¨ 70 @ i ' 12 + max $ 974; $ 825 * (1 + i) 70- 66.5 p 3.5 66.5 * a ¨ 66.5 @ i ' 12 a ¨ 70 @ i ' 12 * a ¨ 70 @ i ' 12 * v i 70- 67 The NCs are computed as follows: N C f o r y e a r 2015 = $ 974 + max 0; $ 887 * 1 + i 70- 67.5 p 2.5 67.5 * a ¨ 67.5 @ i ' 12 a ¨ 70 @ i ' 12- $ 974 * a ¨ 70 @ i ' 12 * v i 70- 67 This can be simplified to: N C f o r y e a r 2015 = m a x $ 974 * a ¨ 70 @ i ' 12 * v i 3; $ 887 * v i 0.5 p 2.5 67.5 * a ¨ 67.5 @ i ' 12 N C f o r y e a r 2016 = max $ 974 * a ¨ 70 @ i ' 12 * v i 2; $ 936 * v i 0.5 p 1.5 68.5 * a ¨ 68.5 @ i ' 12 N C f o r y e a r 2017 = max $ 974 * a ¨ 70 @ i ' 12 * v i; $ 974 * v i 0.5 p 0.5 69.5 * a ¨ 69.5 @ i ' 12 Example 2 An individual participates in a single-employer DB RPP. ... Plan provisions Plan provisions Plan effective date: January 1, 2005 Benefit formula: 2.0% of indexed earnings for each calendar year Normal retirement age: 65 Normal form of pension: Joint and survivor with 66 2/3% survivor pension and guaranteed for 5 years Post-retirement indexing: Fully indexed to CPI Provision of DB limit projection: Yes Actuarial equivalence for delayed retirement: Yes Employee data Employee Data Shareholder (Y/N): Yes; (connected person) Sex: Male Date of birth: October 1, 1948 Date of hire: January 1, 2005 Normal retirement date: October 1, 2013 Attained age: 66.25 Pensionable service: 10 years Pensionable earnings: Maximum for all years Actuarial assumptions Actuarial assumptions Purpose of the valuation Maximum funding valuation under subsections 8515(6) and (7) of the Regulations Valuation date: January 1, 2015 Valuation rate (before retirement): i = 7.5% Salary increase: s = 5.5% Inflation rate (that is CPI): 4.0% Indexation of pension: CPI-1% Valuation rate (after retirement): i ' = 4.37% (1.075/1.03 – 1) DB limit projection rate: 5.5% per annum after 2015 Mortality table: GAM83 Unisex 50% males and 50% females, 80% mortality rates (post-retirement only) Retirement date: January 1, 2018 Retirement age: 69.25 Spouse’s age Same as member Funding method: Projected Accrued Benefit Payment mode of retirement benefits: Monthly, in advance Mode of payment of normal cost (NC): Lump sum at the beginning of the year Review Review B 65 = $ 2,697 * 8.75 = $ 23,599 b 65.25 65 ≤ S v c < 65.25 accrued in 2013 = $ 2,697 * 0.25 = $ 674 b 66.25 65.25 ≤ S v c < 66.25 accrued in 2014 = $ 2,770 * 1 = $ 2,770 b 67.25 66.25 ≤ S v c < 67.25 accrued in 2015 = $ 2,819 * 1 = $ 2,819 b 68.25 67.25 ≤ S v c < 68.25 accrued in 2016 = $ 2,819 * 1.055 * 1 = $ 2,974 b 69.25 68.25 ≤ S v c < 69.25 accrued in 2017 = $ 2,819 * 1.055 2 * 1 = $ 3,138 b 69.25 payable as of January 1, 2018 = $ 2,819 * 1.055 3 * 1 = $ 3,310 B 69.25 S v c < 65 = $ 2,819 * 1.055 3 * 8.75 = $ 28,964 We have used the member’s age in the middle of the year of accrual for the adjustment factors and the maximum pension allowed under subsection 8504(1) of the Regulations during the year of accrual for periods of service after 65. ...
Current CRA website
Actuarial Bulletin No. 1R1
The individual became a member of the plan on January 1, 2005, turned 65 years old on January 1, 2013, and has decided to delay his retirement. ... Plan provisions Example 1: Plan Provisions Plan effective date: January 1, 1991 Benefit formula: Minimum of 1.5% of final average earnings over 3 years (FAE3), or the maximum pension limit times the years of credited service Normal retirement age: 65 Normal form of pension: Life only Post-retirement indexing: Fully indexed to the consumer price index (CPI) Provision of DB limit projection: Yes Actuarial equivalence for delayed retirement: Yes Employee data Example 1: Employee Data Shareholder (Y/N): No (non-connected person) Sex: Male Date of birth: January 1, 1948 Date of hire: January 1, 2005 Attained age: 67 Pensionable service: 10 years Example 1: Employee Earning Data Year Earnings FAE3 (at January 1) 2005- 2012 $50,000- 2013 $55,000 $50,000 2014 $60,000 $51,667 2015 (expected) $62,400* $55,000 2016 (expected) $64,896* $59,133 2017 (expected) $67,492* $62,432 2018- $64,929 *based on assumed salary increase rate Actuarial assumptions Example 1: Actuarial assumptions Valuation date: January 1, 2015 Valuation rate (before retirement): i = 6% Salary increase: s = 4% Inflation rate (that is CPI): 2.50% Indexation of pension: CPI % Valuation rate (after retirement): i ' = 3.41% (1.06/1.025 – 1) DB limit projection rate: 3% per year Mortality table: CPM2014 with mortality improvement scale CPM-B (post-retirement only) Retirement date: January 1, 2018 Retirement age: 70 Funding method: Projected Accrued Benefit Payment mode of retirement benefits: Monthly, in advance Mode of payment of normal cost (NC): Lump sum at the beginning of the year Review Example 1: Review B 65 payable as of January 1, 2013 = 1.5 % * $ 50,000 * 8 = $ 6,000 b 66 65 ≤ S v c < 66 payable as of January 1, 2014 = 1.5 % * $ 51,667 * 1 = $ 775 b 67 66 ≤ S v c < 67 payable as of January 1, 2015 = 1.5 % * $ 55,000 * 1 = $ 825 b 68 67 ≤ S v c < 68 payable as of January 1, 2016 = 1.5 % * $ 59,133 * 1 = $ 887 b 69 68 ≤ S v c < 69 payable as of January 1, 2017 = 1.5 % * $ 62,432 * 1 = $ 936 b 70 69 ≤ S v c < 70 payable as of January 1, 2018 = 1.5 % * $ 64,929 * 1 = $ 974 b 70 payable as of January 1, 2018 = 1.5 % * $ 64,929 * 1 = $ 974 B 70 S v c < 65 = 1.5 % * $ 64,929 * 8 = $ 7,791 The actuarial liability (AL) as at the valuation date is determined as follows: A L @ 1 / 1 / 2015 = (($ 7,791 + max (0; $ 6,000 * (1 + i) 70- 65 5 P 65 * a ¨ 65 @ i ' (12) a ¨ 70 @ i ' (12)- $ 7,791)) + ($ 974 + max (0; $ 775 * (1 + i) 70- 65.5 4.5 P 65.5 * a ¨ 65.5 @ i ' (12) a ¨ 70 @ i ' (12)- $ 974)) + ($ 974 + max (0; $ 825 * (1 + i) 70- 66.5 3.5 P 66.5 * a ¨ 66.5 @ i ' (12) a ¨ 70 @ i ' (12)- $ 974))) * a ¨ 70 @ i ' (12) * v i 70- 67 This can be simplified to: A L @ 1 / 1 / 2015 = (max ($ 7,791; $ 6,000 * (1 + i) 70- 65 5 P 65 * a ¨ 65 @ i ' (12) a ¨ 70 @ i ' (12)) + max ($ 974; $ 775 * (1 + i) 70- 65.5 4.5 P 65.5 * a ¨ 65.5 @ i ' (12) a ¨ 70 @ i ' (12)) + max ($ 974; $ 825 * (1 + i) 70- 66.5 3.5 P 66.5 * a ¨ 66.5 @ i ' (12) a ¨ 70 @ i ' (12))) * a ¨ 70 @ i ' (12) * v i 70- 67 The NCs are computed as follows: N C f o r y e a r 2015 = ($ 974 + max (0; $ 887 * (1 + i) 70- 67.5 2.5 P 67.5 * a ¨ 67.5 @ i ' (12) a ¨ 70 @ i ' (12)- $ 974)) * a ¨ 70 @ i ' (12) * v i 70- 67 This can be simplified to: N C f o r y e a r 2015 = max ( $ 974 * a ¨ 70 @ i ' (12) * v i 3; $ 887 * v i 0.5 2.5 P 67.5 * a ¨ 67.5 @ i ' (12)) N C f o r y e a r 2016 = max ($ 974 * a ¨ 70 @ i ' (12) * v i 2; $ 936 * v i 0.5 1.5 P 68.5 * a ¨ 68.5 @ i ' (12)) N C f o r y e a r 2017 = max ($ 974 * a ¨ 70 @ i ' (12) * v i; $ 974 * v i 0.5 0.5 P 69.5 * a ¨ 69.5 @ i ' (12)) Example 2 An individual participates in a single-employer DB RPP. ... Plan provisions Example 2: Plan provisions Plan effective date: January 1, 2005 Benefit formula: 2.0% of indexed earnings for each calendar year Normal retirement age: 65 Normal form of pension: Joint and survivor with 66 2/3% survivor pension and guaranteed for 5 years Post-retirement indexing: Fully indexed to CPI Provision of DB limit projection: Yes Actuarial equivalence for delayed retirement: Yes Employee data Example 2: Employee Data Shareholder (Y/N): Yes; (connected person) Sex: Male Date of birth: October 1, 1948 Date of hire: January 1, 2005 Normal retirement date: October 1, 2013 Attained age: 66.25 Pensionable service: 10 years Pensionable earnings: Maximum for all years Actuarial assumptions Example 2: Actuarial assumptions Purpose of the valuation: Maximum funding valuation under subsections 8515(6) and (7) of the Regulations Valuation date: January 1, 2015 Valuation rate (before retirement): i = 7.5% Salary increase: s = 5.5% Inflation rate (that is CPI): 4.0% Indexation of pension: CPI-1% Valuation rate (after retirement): i ' = 4.37% (1.075/1.03 – 1) DB limit projection rate: 5.5% per annum after 2015 Mortality table: GAM83 Unisex 50% males and 50% females, 80% mortality rates (post-retirement only) Retirement date: January 1, 2018 Retirement age: 69.25 Spouse’s age: Same as member Funding method: Projected Accrued Benefit Payment mode of retirement benefits: Monthly, in advance Mode of payment of normal cost (NC): Lump sum at the beginning of the year Review Example 2: Review B 65 = $ 2,697 * 8.75 = $ 23,599 b 65.25 65 ≤ S v c < 65.25 accrued in 2013 = $ 2,697 * 0.25 = $ 674 b 66.25 65.25 ≤ S v c < 66.25 accrued in 2014 = $ 2,770 * 1 = $ 2,770 b 67.25 66.25 ≤ S v c < 67.25 accrued in 2015 = $ 2,819 * 1 = $ 2,819 b 68.25 67.25 ≤ S v c < 68.25 accrued in 2016 = $ 2,819 * 1.055 * 1 = $ 2,974 b 69.25 68.25 ≤ S v c < 69.25 accrued in 2017 = $ 2,819 * 1.055 2 * 1 = $ 3,138 b 69.25 payable as of January 1, 2018 = $ 2,819 * 1.055 3 * 1 = $ 3,310 B 69.25 S v c < 65 = $ 2,819 * 1.055 3 * 8.75 = $ 28,964 We have used the member’s age in the middle of the year of accrual for the adjustment factors and the maximum pension allowed under subsection 8504(1) of the Regulations during the year of accrual for periods of service after 65. ...
Current CRA website
Tax Appeals Evaluation
Individuals within this group had filed tax returns in 2005 and/or 2006 claiming that they had made a charitable donation during that year(s). ... Code 7-6 – Invalid – other Used when a case is closed for a reason that does not fall under any other code. ... Code 6 – Withdrawn-discontinued – Confirmed An appeal having been confirmed by the judge because an appellant withdrew or discontinued the appeal. ...
Current CRA website
What constitutes an "other body established by a government" for purposes of the Excise Tax Act (the Act)?
Government A passed legislation—the Safe Consumers Act (SCA) Footnote * —on January 10, 2002. ... Prior to passage of the SCA, Government A issued licences to businesses in the specific industry pursuant to the Consumer Protection and Safety Act Footnote *. ... Footnote * Pursuant to the SCA, Government A retained the responsibility for legislating the overall regulatory framework for the specific industry. ...
Current CRA website
Chapter History
Update March 28, 2013 General Income Tax Folio S5-F2-C1, Foreign Tax Credit consolidates, replaces, and cancels Interpretation Bulletin IT-270R3, Foreign Tax Credit, Interpretation Bulletin IT-395R2, Foreign Tax Credit – Foreign-Source Capital Gains and Losses, and Interpretation Bulletin IT-520 (consolidated), Unused Foreign Tax Credits – Carryforward and Carryback. ... The reference to resource royalties was removed from the discussion of taxes in general since they may be a payment for a specific right or privilege, or may be part of a regulatory scheme and moved to the discussion of examples of what will not be considered an income or profits tax, to address the situation where they may be structured as a tax. ¶1.6 (formerly included in ¶5 of IT-270R3) now includes an additional bullet to reflect the operation of subsection 126(4). ¶1.7 (formerly included in ¶5 of IT-270R3) has been revised to reflect the primacy of Canadian law for characterizing a transaction, and calculating the income for the purposes granting a foreign tax credit in accordance with the language of section 126. ¶1.9 (formerly included in ¶5 of IT-270R3) now includes a reference to documentary or stamp taxes in the examples of items not considered to be income or profits taxes in consideration of the CRA’s position on the general nature of these taxes. ¶1.10 (formerly included in ¶5 of IT-270R3) has been revised to change business income to net business income in the first sentence for greater clarity. ¶1.16 (formerly included in ¶7 of IT-270R3) now includes an example describing a taxpayer with different taxing and business countries. ¶1.25 (formerly included in ¶8 of IT-270R3) has been reworded to remove ambiguity as to whether foreign was meant to describe the other person or partnership and to better reflect paragraph (e) of the definition of non-business-income tax in subsection 126(7). ¶1.26 (formerly included in ¶8 of IT-270R3) now includes a reference to the amendments to the overseas employment tax credit contained in the Jobs and Growth Act, 2012; edited to remove redundancy. ¶1.29- 1.31 are new additions which replace and expand on the parenthetical comment in ¶8 of IT-270R3, which read: (subject to subsections 126(4.1) and (4.2), which concern the no economic profit and short-term security acquisitions rules, respectively) ¶1.32- 1.35 (formerly included in ¶11 of IT-270R3) has been revised to omit the last sentence of former ¶11 and to add a discussion on what is meant by paid by the taxpayer for the year. ¶1.39 replaces and expands on the partnership information contained within parenthesis at ¶1- 2 of IT-270R3. ¶1.41 (formerly included in ¶15 of IT-270R3) has been revised to de-emphasize the word spouse and place greater emphasis on the filing of a valid, foreign, communal return. ¶1.42 (formerly included in ¶16 of IT-270R3) has been expanded to reflect amendments to section 261 and the CRA’s position regarding consistency in exchange rate methodologies. ¶1.46 (formerly included in ¶20 of IT-270R3) has been revised to clarify the situation of income arising from property which pertains to or is incidental to a foreign business. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...
Current CRA website
Chapter History S5-F2-C1, Foreign Tax Credit
Update March 28, 2013 General Income Tax Folio S5-F2-C1, Foreign Tax Credit consolidates, replaces, and cancels Interpretation Bulletin IT-270R3, Foreign Tax Credit, Interpretation Bulletin IT-395R2, Foreign Tax Credit – Foreign-Source Capital Gains and Losses, and Interpretation Bulletin IT-520 (consolidated), Unused Foreign Tax Credits – Carryforward and Carryback. ... The reference to resource royalties was removed from the discussion of taxes in general since they may be a payment for a specific right or privilege, or may be part of a regulatory scheme and moved to the discussion of examples of what will not be considered an income or profits tax, to address the situation where they may be structured as a tax. ¶1.6 (formerly included in ¶5 of IT-270R3) now includes an additional bullet to reflect the operation of subsection 126(4). ¶1.7 (formerly included in ¶5 of IT-270R3) has been revised to reflect the primacy of Canadian law for characterizing a transaction, and calculating the income for the purposes granting a foreign tax credit in accordance with the language of section 126. ¶1.9 (formerly included in ¶5 of IT-270R3) now includes a reference to documentary or stamp taxes in the examples of items not considered to be income or profits taxes in consideration of the CRA’s position on the general nature of these taxes. ¶1.10 (formerly included in ¶5 of IT-270R3) has been revised to change business income to net business income in the first sentence for greater clarity. ¶1.16 (formerly included in ¶7 of IT-270R3) now includes an example describing a taxpayer with different taxing and business countries. ¶1.25 (formerly included in ¶8 of IT-270R3) has been reworded to remove ambiguity as to whether foreign was meant to describe the other person or partnership and to better reflect paragraph (e) of the definition of non-business-income tax in subsection 126(7). ¶1.26 (formerly included in ¶8 of IT-270R3) now includes a reference to the amendments to the overseas employment tax credit contained in the Jobs and Growth Act, 2012; edited to remove redundancy. ¶1.29- 1.31 are new additions which replace and expand on the parenthetical comment in ¶8 of IT-270R3, which read: (subject to subsections 126(4.1) and (4.2), which concern the no economic profit and short-term security acquisitions rules, respectively) ¶1.32- 1.35 (formerly included in ¶11 of IT-270R3) has been revised to omit the last sentence of former ¶11 and to add a discussion on what is meant by paid by the taxpayer for the year. ¶1.39 replaces and expands on the partnership information contained within parenthesis at ¶1- 2 of IT-270R3. ¶1.41 (formerly included in ¶15 of IT-270R3) has been revised to de-emphasize the word spouse and place greater emphasis on the filing of a valid, foreign, communal return. ¶1.42 (formerly included in ¶16 of IT-270R3) has been expanded to reflect amendments to section 261 and the CRA’s position regarding consistency in exchange rate methodologies. ¶1.46 (formerly included in ¶20 of IT-270R3) has been revised to clarify the situation of income arising from property which pertains to or is incidental to a foreign business. ¶1.49 (formerly included in ¶21 of IT-270R3) now references the Canada-UK Income Tax Convention. ¶1.51 (formerly included in ¶22 of IT-270R3) now contains a sentence to address subsection 91(5). ¶1.52 is a new paragraph added to point out that where a treaty is applicable; the treaty may have its own income sourcing rules which supersede those of the Act, but only for the purposes of eliminating double taxation in accordance with the treaty. ¶1.53 (formerly included in ¶23 of IT-270R3) now includes the phrase or profit generating activities for greater clarity, as well as a bullet referencing transportation or shipping businesses. ¶1.54 is a new paragraph added to reflect the jurisprudence on additional factors and the weighting of various factors when determining the location of the source of the business income. ¶1.57 (formerly included in ¶25 of IT-270R3) has been revised to change place to physical place to remove ambiguity. ¶1.58 (formerly included in ¶26 of IT-270R3) contains new sentences that reflect additional factors concerning the situs of income and their weight, as judicially addressed. ¶1.62 (formerly included in ¶3 of IT-395R2) has been revised to add and title was transferred to the second sentence and to add the third sentence for greater clarity. ¶1.63 (formerly included in ¶3 of IT-395R2) has been revised to add the phrase under the Act to remove ambiguity and to differentiate between foreign deemed dispositions and deemed dispositions under domestic law. ¶1.65 (formerly included in ¶4 of IT-395R2) now includes examples and a discussion of the relative weighting of various factors for consideration. ¶1.69 is a new paragraph added to address TFSAs and RRSPs. ¶1.70- 1.72 (formerly included in ¶37 of IT-270R3) has been revised to reflect legislative changes effective for the 2005 and later tax years, to make reference to the additional definitions involved, and to reference Guide 5000-G, General Income Tax and Benefit Guide. ¶1.73 (formerly included in ¶40 of IT-270R3) has been revised to change the treaty in the example to the Canada-India Treaty. ¶1.76 (formerly included in ¶2 of IT-270R3) has been revised to match the marginal note of subsection 120(1). ¶1.79 (formerly included in ¶3 of IT-270R3) has been expanded to better explain the operation of section 114 and subparagraphs 126(1)(b)(ii) and 126(2.1)(a)(ii). ¶1.80 (formerly included in ¶30 of IT-270R3) now includes the phrase not under the laws of the foreign jurisdiction in the first paragraph for greater clarity. ...
Current CRA website
RPP Practitioners' Forum - Questions from the Industry June 3, 2008
Answer 7: As indicated in our answer to Question 12 of the 2005 Consultation Session, any current surplus under a defined-benefit pension plan as a whole should be fully utilized before any additional contributions are permitted to fund the liability for surplus entitlements on partial wind-up resulting from the Monsanto decision. ... Answer 13: Go to the RPD Technical Manual, 5.1 147.4(1) – RPP Annuity Contract and the Newsletter no.16-3, Transfers from underfunded individual pension plans. ... Answer 16: Go to the RPD Technical Manual, 2.18 147.1(19) – Reasonable error and 8.4 8502(d) – Permissible Distributions. ...