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Bundle Date Translated severed letter Summaries under Summary descriptor 2013-03-20 19 December 2012 External T.I. 2011-0425581E5 F- CII- régions admissibles-Montérégie-Rive-Sud Income Tax Act- Section 127- Subsection 127(9)- Specified Percentage description of qualifying ITC regions (which exclude Montérégie South Shore) 24 October 2012 External T.I. 2012-0443721E5 F- Compensation- vente d'un immeuble Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Damages taxpayer need not have attempted to prevent the act or omission resulting in the damages 20 February 2013 External T.I. 2012-0473051E5 F- Frais de gestion versés à un conjoint Income Tax Act- Section 67 determining reasonableness of spousal management fee entails a “comparison to an amount paid for similar services according to industry standards” 27 November 2012 External T.I. 2012-0445941E5 F- Action déterminée de petite entreprise Income Tax Act- Section 44.1- Subsection 44.1(1)- Qualifying Disposition shares issued to a family trust do not qualify as "eligible small business corporation shares" 25 February 2013 Internal T.I. 2012-0440371I7 F- Changement d'usage- Duplex Income Tax Act- Section 45- Subsection 45(3) s. 45(3) election unavailable for partial change of use (duplex going from 50% to 100% personal use) 11 February 2013 External T.I. 2012-0469441E5 F- Aire de plancher- fabrication et transformation Income Tax Regulations- Regulation 1100- Subsection 1100(1)- Paragraph 1100(1)(a.1) washrooms and cafeteria included- along with office if a connection with the M&P personnel ...

Art. 12 of the Canada-U.K Treaty exempted copyright royalties, but there was an exclusion from this exemption for payments in respect of motion pictures or of works on film, videotape or other means of reproduction for use in connection with television broadcasting. ...

Rousseau left Quebec solely for work purposes and that he never had the intention to sever his connections with Quebec, which was the place with which he maintained his strongest links between 2003 and 2011. ...

14 November 2018- 11:44pm CRA confirms that amounts derived from a related business do not include capital gains from the passive investment of the dividends therefrom Email this Content S. 120.4(1.1)(d) provides that an amount derived directly or indirectly from a business includes an amount that: is derived from the provision of property or services to, or in support of, the business, or arises in connection with the ownership or disposition of an interest in the person or partnership carrying on the business, or is derived from an amount described [above] Notably, it does not reference an amount arising from the disposition of property whose acquisition was funded with dividends from the business. ...

However, this was essentially irrelevant to the point that the implied waivers nonetheless had been given (albeit, in connection with objecting to reassessments that were replaced by, and, therefore, voided by, the second reassessments.) ...

That arrangement took place in Australia, and accordingly, because the scheme was the “proximate” origin of the profits earned, and because of the other connections with Australia summarised by the primary judge … including the location of the mine in Western Australia, those profits had a source in Australia. ...

However, two months later, the taxpayer borrowed a larger sum in connection with subscribing for and acquiring common shares of Vidabode in order inter alia to fund the repayment by Vidabode of the GE Capital loans. ...

In rejecting Roofmart’s reliance on the statement in Hydro-Québec that "[w]hen the group is generic and has no connection to the ITA, and information can be requested outside of the scope of the ITA (such as identifying the business clients of a public utility) there is no longer any limit on the fishing expedition," Rennie JA stated that this “passage is not a legal test but analysis of whether, on the facts of that case, there was an ‘ascertainable group’ and whether the information was required for the purposes of verifying compliance,” and that ”the suggestion in the reasons that the information sought was available through other means and therefore could not be obtained through a UPR [unnamed person requirement] is inconsistent with this Court’s jurisprudence, and ought not to be followed.” ...

After referencing the Saipem test of “a rational connection … between the information sought and the administration and enforcement of the ITA,” Fothergill J pared back the terms of the requirement to something roughly comparable to what CRA had previously asked for, and with a further limitation that Bayer Canada was only required to produce Bayer-Group agreements with 21 pharmaceutical companies that had been specifically named by CRA. ...

14 July 2020- 11:44pm Marino – Tax Court of Canada finds that an individual not within s. 2(1) or (3) was not a taxpayer who could generate a tuition tax credit Email this Content An individual with no connection to Canada paid a lot in tuition fees while in attendance at U.S. universities prior to 2012 then, on immigrating to Canada, claimed his purported unused tuition tax credits as a deduction from Canadian tax. ...