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2 February 2005 Internal T.I. 2005-0111961I7 F- Reassessment of a Partner-- summary under Subsection 152(1.4) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1.4) CRA can assess a partner directly to change the partnership income allocable to it rather than being required to make a partnership-level determination under s. 152(1.4) The latest date by which the Minister could make a determination at the level of a limited partnership (BCOM) for its 2001 fiscal year pursuant to s. 152(1.4) was February 28, 2005, whereas the normal reassessment period for its general partner (XCO) for its taxation year in which the BCOM's 2001 fiscal period ended (the "Particular Taxation Year"), would expire on April 25, 2005. Regarding whether the Minister could reassess XCO directly to change the partnership income allocated to it, the Directorate stated: [T]he Minister could reassess pursuant to subsection 152(4) at the level of the XCO general partner, in respect of the tax that would be payable by XCO for the Particular Taxation Year, in order to, inter alia, modify the amount of its share of the income from BCOM that was included in the computation of its income … without a determination being made at the level of BCOM pursuant to subsection 152(1.4), and without assessments at the level of BCOM partners being made pursuant to paragraph 152(1.7)(b). ...

3 May 2005 External T.I. 2005-0124261E5- Employee Stock Purchase Plan-- summary under Paragraph 7(3)(b) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(3)- Paragraph 7(3)(b) s. 7(3)(b) applies to trusteed treasury share, but not open-market purchase, plan A corporate employer contribute amounts to a newly-established trust from time to time, and the trustee uses those contributions to acquire shares of the employer from the employer or non-arm’s length shareholders thereof. ... To clarify…where it is evident, from its inception, that the arrangement is subject to subsection 7 of the Act, it is our view that an employer cannot deduct any amounts with respect to any contributions made by the employer under the arrangement. … [However] section 7… will not apply to situations where an employer contributes an amount to a trust and the trust uses the funds to acquire shares through open market transactions. ...

18 April 2005 External T.I. 2004-0093821E5 F- Fiducie créée par testament-- summary under Subparagraph (c)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Testamentary Trust- Paragraph (c)- Subparagraph (c)(i) beneficiary electing not to receive income before it becomes payable does not taint the trust (cf. renouncing income already payable) Under a spouse trust, the spouse has the exclusive and unconditional right to all annual income but it remains in the spouse's discretion to not require the annual payment of all income, and any portion of the income not so distributed to be added to the trust capital distributed to the spouse, at the spouse's discretion, in the same manner as the capital, the spouse being the sole capital beneficiary during the spouse’s lifetime, so that the trustees must distribute all or part of the capital to the spouse at the spouse’s sole request. ... Thus, in such a situation, the trust would no longer be a "testamentary trust" …. ...

16 May 2005 Internal T.I. 2005-0119061I7 F- Montant d'aide-actions-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1)- Excluded Obligation- Paragraph (a) conversion of loan that was taxable assistance under s. 12(1)(x) into shares with lower FMV would not give rise to forgiven amount Prod Co, a wholly owned subsidiary of M Co and a "qualified corporation," produces a Canadian film or video production ("CFVP") at a cost of $1,900,000 that is eligible for the s. 125.4(3) credit. ... Since … the loan from M Co is assistance that is required to be included in Prod Co's income under paragraph 12(1)(x), the conversion of the loan by M Co into shares of Prod Co at the end of the production would not engage the application of subsection 80(2). ...

7 October 2005 Roundtable, 2005-0138111C6 F- Actions donnant droit au produit d'assurance-vie-- summary under Subsection 70(5) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(5) the CSV of a life insurance policy could reasonably be fully allocated on the death of a common shareholder to the holder of a tracking share The taxpayer wants the proceeds of the universal life insurance policy on his life paid on his death to his adult child, rather than to his spouse, who is the one under his will to inherit his shares of the private corporation (the “Corporation”) that will be the policyholder and beneficiary. ... CRA confirmed that, regarding the narrow issue of the FMV of the common shares immediately before the death of the taxpayer, given that the insurance share was retractable by the holder immediately before the death for the CSV, it would not be unreasonable to allocate the policy CSV to the insurance shares – so that the value of the common shares would not take the policy CSV into account. ...

8 November 2005 External T.I. 2005-0148091E5 F- Résidence principale-deux unités de condominium-- summary under Principal Residence Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence two stacked condos connected by an interior staircase constituted two housing units A couple purchased a condo beneath the one they had been occupying as their home and did work to connect the two units by interior staircase. ... On the other hand, if one unit has all the bedrooms and the other unit consists primarily of the kitchen and bathrooms and they are truly used as one unit, the CRA may be more likely to conclude that there is a single unit for purposes of the definition of "principal residence" …. ...