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4 February 2015 Internal T.I. 2014-0520721I7 - Indian Tax Exemption - Business Income -- summary under Section 87

After comparing these facts with Dickie v The Queen, 2012 TCC 242, CRA stated: The extent to which the managerial activities, not just those of the Taxpayers, were performed on a reserve will need to be considered. ...

19 January 2015 External T.I. 2014-0547271E5 F - SERP and Lump-Sum Averaging -- summary under Superannuation or Pension Benefit

Generally, when such a plan is funded, it is considered a retirement compensation arrangement. ...

9 May 2013 External T.I. 2012-0435401E5 F - Server as a PE in a province -- summary under Subsection 400(2)

The place of business must also be considered fixed, which requires a certain degree of permanence. ...

19 January 2015 External T.I. 2014-0549061E5 F - logement des employés -- summary under Paragraph 6(6)(a)

. … [S.. 6(6)(a)(ii) is unavailable as] generally, a location is considered remote if the nearest established community of 1,000 or more is at least 80 kilometers (50 miles) by the most direct route normally taken in the circumstances. ...

24 December 2013 Internal T.I. 2013-0512551I7 - Thin Cap and partnership income -- summary under Subsection 18(4)

The correspondent considered that the retained earnings of ULC should exclude its proportionate share of the Partnership income for the stub period on the basis that " 2007-0248961R3 indicate[s]... that section 96 informs the determination of the amount of partnership income to be included in determining the amount of a corporate partner's retained earnings for the purpose of the thin capitalization rules. ...

11 October 2013 APFF Roundtable, 2013-0493651C6 F - Affiliated persons and de facto control -- summary under Subsection 256(5.1)

" CRA also noted [TaxInterpretations translation] that although IT-64R4 indicates that the holding of a large debt is relevant to determining whether the holder has de facto control of the debtor: This factor nonetheless was considered of little importance in Technical Interpretation XXX where the debt represented virtually all the net value of a corporation but all its assets consisted of readily marketable securities which could serve to repay the debt held by an estate without imperiling its investment operations. ...

11 October 2013 APFF Roundtable, 2013-0495781C6 F - GRIP Exceeds Safe Income -- summary under Excessive Eligible Dividend Designation

Respecting whether Targetco would be considered to have made an "excessive eligible dividend designation" under (c) of the definition, CRA stated (TaxInterpretations translation): In the situation described above, Targetco is the only corporation which will pay a dividend and whose GRIP will be reduced. ...

5 October 2012 Roundtable, 2012-0451271C6 F - Residence of a trust -- summary under Subsection 2(1)

This approach appears to us to be further justified by the fact that the determination of the place of residence of a trust, although generally made at one time, may require that factors and factual elements relating to an extended period be considered. … [T]he fact that a person advises a trustee should not in itself generally alter the location of central management and control of the trust at the trustee level. ...

5 October 2012 Roundtable, 2012-0454021C6 F - Expiration d'un arrangement -- summary under Subsection 6205(2)

In this context, what is an "arrangement" and when is it can be considered to end? ...

26 August 2014 External T.I. 2014-0528701E5 - Non-profit organization - Condominium -- summary under Paragraph 149(1)(l)

Generally, the carrying on of a trade or business directly attributable to, or connected with, pursuing the non-profit goals and activities of an association will not cause it to be considered to be operated for profit purposes. ...

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