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4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement Unedited CRA Tags 87(4), 87(8), 87(8.4), 87(8.5). ... XXXXXXXXXX 2025-105373 Yannick Roulier March 4, 2025 Dear XXXXXXXXXX: Re: DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement We are writing in reply to your email dated February 14, 2025, in which you suggested that a particular statement made in the Department of Finance’s explanatory notes seems to be inconsistent with a technical reading of the legislation. ...

12 March 2025 External T.I. 2025-1053231E5- Effects of a Power of Attorney on TOSI Unedited CRA Tags 120.4(1) "excluded shares" Principal Issues: Whether a Power of Attorney would affect the ownership of shares with respect to the definition of "excluded shares" in subsection 120.4(1). ... Adult Child is an individual who is over 24 years old at the beginning of 2025. 2. ... In 2025, the FT distributes 10 Common shares of Aco to Adult Child under subsection 107(2). ...

11 March 2025 External T.I. 2020-0845931E5 F- Transfert d’une propriété intellectuelle Principales Questions: Quel est le traitement fiscal de sommes reçues par des contribuables lors du transfert d’une propriété intellectuelle dans une situation donnée? ... Fisc. 2020-084593 Le 11 mars 2025 Bonjour, Objet: Transfert d’une propriété intellectuelle Cette lettre est en réponse à votre courriel du 13 avril 2020 dans lequel vous demandez nos commentaires sur le traitement fiscal de sommes reçues par des contribuables lors du transfert d’une propriété intellectuelle dans une situation donnée. ...

25 February 2025 External T.I. 2024-1016651E5- METC and amounts paid to obtain embryos Unedited CRA Tags 118.2(2)(v) Principal Issues: Whether certain amounts paid to obtain embryos would qualify as an eligible medical expense for the purposes of the medical expense tax credit (METC). ... XXXXXXXXX 2024-101665 Chris Brennan, CPA, CA February 25, 2025 Dear XXXXXXXXXX: Re: METC and amounts paid to obtain embryos This is in reply to your email of May 1, 2024 wherein you requested our views on whether certain amounts paid to obtain embryos would qualify as an eligible medical expense pursuant to paragraph 118.2(2)(v) of the Income Tax Act (the Act) for the purposes of the medical expense tax credit (METC). ...

25 March 2025 External T.I. 2025-1049301E5- METC- Hyperbaric oxygen chamber & concentrator Unedited CRA Tags Subsection 118.2(2) ITA; Paragraphs 118.2(2)(i) and (k) ITA; Paragraph 118.4(2)(c) ITA Principal Issues: Whether the amounts paid to acquire 1) a portable oxygen concentrator and 2) a hyperbaric oxygen chamber would qualify as eligible medical expenses for the purposes of the medical expense tax credit (METC). ... XXXXXXXXXX 2025-104930 Éloïse Lafortune Viger March 25, 2025 Dear XXXXXXXXXX, Re: Medical Expense Tax Credit – Portable Oxygen Concentrator and Hyperbaric Oxygen Chamber We are writing in response to your letter dated October 16, 2024, inquiring whether the amounts paid to acquire a portable oxygen concentrator and a hard shell hyperbaric oxygen chamber would qualify as eligible medical expenses under subsection 118.2(2) of the Income Tax Act (the “Act”) for the purposes of the medical expense tax credit (“METC”). ...

14 January 2025 External T.I. 2024-1040541E5- Status of Lands in Additions to Reserve process Unedited CRA Tags ITA para. 81(1)(a); IA s. 87 Principal Issues: Whether the employment income earned from work performed on lands under the Additions to Reserve process is situated on a reserve. ... January 14, 2025 XXXXXXXXXX Phyllis Chiu 2024-104054 Dear XXXXXXXXXX: RE: Employment on lands undergoing the Additions to Reserve process and the tax exemption under section 87 of the Indian Act This is in response to your enquiry asking whether the employment income from work performed at offices located on lands currently going through the Additions to Reserve process (ATR lands) is situated on a reserve and exempt under section 87 of the Indian Act and paragraph 81(1)(a) of the Income Tax Act (Act). ...

21 January 2025 External T.I. 2024-1041441E5- Return of Premium Life Insurance Policy Unedited CRA Tags 56(1)(j), 148(1), 148(9), Reg 308 Principal Issues: We were asked to provide comments on the taxation of a return of premium payment made to a taxpayer by a life insurance company upon the maturity of a term life insurance policy. ... Campbell 2024-104144 January 21, 2025 Dear XXXXXXXXXX: Re: Life Insurance Policy – Return of Premium Benefit We are writing in response to your correspondence dated October 27, 2024, in which you requested our comments on why you were issued a T5 Slip from an insurer with respect to an amount you received upon the maturity of a term life insurance policy. ...

23 January 2025 External T.I. 2024-1030091E5- Specified Corporate Income- Realtor Commissions Unedited CRA Tags 125(1), 125(7) "Specified corporate income" Principal Issues: Whether real estate commissions earned by a personal real estate corporation ("PREC"), which are paid from a brokerage in which the shareholder of the PREC has an indirect interest in, would be described in subparagraph (a)(i) of the definition of specified corporate income in subsection 125(7) of the Act. ... XXXXXXXXXX Income Tax Rulings Directorate Ryan Wallace, CPA 2024-103009 January 23, 2025 Dear XXXXXXXXXX: We are writing in response to your email on July 16, 2024, wherein you requested our views on whether commission income of a personal real estate corporation (“PREC”) received from a real estate brokerage would be considered specified corporate income (“SCI”), as that term is defined in subsection 125(7) of the Income Tax Act (the “Act”), and whether receiving this income would impact the PREC’s small business deduction (“SBD”). ...

7 February 2025 External T.I. 2024-1034651E5- Indian Act Tax Exemption- Retroactive salary Unedited CRA Tags ITA para. 81(1)(a); IA s. 87 Principal Issues: Whether a lump-sum payment for retroactive salary increases received is exempt under section 87 of the Indian Act and paragraph 81(1)(a) of the Act. ... XXXXXXXXXX Phyllis Chiu 2024-103465 February 7, 2025 Dear XXXXXXXXXX: RE: Lump-sum payment for retroactive salary increase This is in response to your email correspondence asking whether a lump-sum retroactive salary increase (Retroactive Payment) paid to an employee (Employee) of the XXXXXXXXXX (Employer) is exempt from income tax under section 87 of the Indian Act and paragraph 81(1)(a) of the Income Tax Act (Act). ...

31 January 2025 External T.I. 2024-1024421E5- Registered charities and 149(1)(l) Unedited CRA Tags 149(1)(l) Principal Issues: The filing requirements for a registered charity and non-profit organization. ... XXXXXXXXXX 2024-102442 Karri Lea Estabrooks January 31, 2025 Dear XXXXXXXXXX: Re: Registered charities and non-profit organizations – filing requirements We are writing in response to your correspondence of June 24, 2024, where you requested our comments on the filing requirements for a registered charity and non-profit organization in the following described situation. ...