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13 April 2005 Internal T.I. 2004-0109071I7 F- Partie XIII et revenus locatifs-- summary under Subsection 216(4) Summary Under Tax Topics- Income Tax Act- Section 216- Subsection 216(4) services provided by property manager to tenant were sufficiently limited to permit making the s. 216(4) election A property manager agreed with the owners of condos, including the non-resident owner in question, to rent out the condo on behalf of the owner, and pay the rents collected by it net of expenses to the owner. ... Regarding such election, the Directorate stated: In order for only the amounts actually paid to the non-resident person to be subject to the 25% withholding, [the property manager] and the non-resident person would have to make an election under subsection 216(4). … [W]e have assumed that the rental income is property income to the non-resident person rather than business income (in which case the rental income would not be subject to Part XIII tax but rather to Part I tax). … [T]he services provided by [the property manager] o the lessees do not appear to be sufficiently important to characterize the rents as business income (see … IT-434R and … Walsh … 65 DTC 5293 (Ex. ...

2 August 2005 External T.I. 2005-0112871E5 F- Cotisation professionnelle-- summary under Subparagraph 8(1)(i)(i) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(i)- Subparagraph 8(1)(i)(i) fees paid by municipal mangers to a professionals corporation formed under private member’s bill were non-deductible The Municipal Officers' Corporation of Quebec ("COMAQ"), a professionals corporation incorporated under a private act, had over 550 members who were managers in over 250 municipalities and who were required to pay an annual fee to remain a member and enjoy the status of certified municipal officer. In finding that the fees were not deductible under s. 8(1)(i)(i), CRA stated: IT-158R2, [para. 1(c) … states that professional status must be recognized by a Canadian, provincial or foreign statute. ... [T]he facts described … do not support the conclusion that those conditions are satisfied. ...

16 February 2005 External T.I. 2004-0097161E5 F- Fin d'exercice d'une société de personnes-- summary under Paragraph 249.1(4)(b) Summary Under Tax Topics- Income Tax Act- Section 249.1- Subsection 249.1(4)- Paragraph 249.1(4)(b) requirement that there not be a multi-tier partnership must be satisfied each fiscal period Partnership A is owned by four partners who are all individuals. ... CRA responded: [T]he conditions in the preamble to subsection 249.1(4) must … be … satisfied in each of the fiscal periods following that first fiscal period of the business in order for subsection 249.1(4) to continue to apply …. Among the conditions … [is that] each member of the partnership is an individual and the partnership is not a member of another partnership. … [W]hen Partnership A became a member of Partnership B, the two partnerships no longer satisfied the conditions of subsection 249.1(4) for the current fiscal period …. ...

19 October 2005 Internal T.I. 2005-0151211I7- Financing expenses-- summary under Paragraph 20(1)(e.1) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(e.1) indirect use test inapplicable to s. 20(1)(e) or (e.1), and “relate solely to … year” test not satisfied by lump sum issue fee reimbursement to parent A Co, a public company, issued interest-bearing debentures to arm's length parties, and on-lent the borrowed money to its "great-grandchild" subsidiary (D Co) at the same interest rate. ...

17 August 2005 External T.I. 2005-0135911E5 F- REEE- Établissement d'enseignement à l'étranger-- summary under Post-Secondary Educational Institution Summary Under Tax Topics- Income Tax Act- Section 146.1- Subsection 146.1(1)- Post-Secondary Educational Institution a foreign educational institution that is listed in the American Council on Education's Accredited Institutions of Postsecondary Education will be recognized as a "post-secondary educational institution" Must a U.S. post-secondary institution be listed in the current edition of the Accredited Institutions of Postsecondary Education published by the American Council on Education in order to qualify as a designated eligible institution for purposes of the definition of post-secondary educational institution? ... However, a foreign educational institution that is [so] listed … will be recognized as a "post-secondary educational institution" …. However, it is the RESP promoter's responsibility to ensure that educational assistance payments under the plan are made in accordance with the conditions of registration set out in paragraph 146.1(2)(g.1). … … If a promoter wishes to obtain confirmation that a foreign educational institution is recognized for the purposes of section 146.1, it may make a request to the following address: …. ...

9 November 2005 Internal T.I. 2005-0154301I7 F- Choix concernant les immobilisations admissibles-- summary under Class 14.1 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 14.1 operating agreement of care facility with province was goodwill because it could not be transferred without a transfer of the care business On a sale of a residential care facility, the taxpayer allocated substantially all of the sale price to operating agreements with the Quebec Ministry, and took the position that the election under s. 14(1.01) (which at the time had provided that the election could be made regarding eligible capital property other than goodwill) was available as the operating agreements represented ECP other than goodwill. ... In return, the MSSS provides the necessary funding for the operation of the institution. … [T]he operating agreements constitute goodwill … since the acquisition of one or more operating agreements by a purchaser can only be made if the Minister … has approved the assignment of the underlying licence. ... Thus, since the transfer of the operating agreements cannot be made without the transfer of the business to the new purchaser, we are of the view that the operating agreements constitute goodwill …. ...