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6 January 2004 External T.I. 2003-0052261E5 - Subparagraph 256(1.2)(f)(ii) -- summary under Subparagraph 256(1.2)(f)(ii)

A be considered to own all the shares of Opco under s. 256(1.2)(f)(ii)? ...

2017 Ruling 2016-0655071R3 - Supplemental employee retirement plan -- summary under Subject Property of a Retirement Compensation Arrangement

CRA ruled that no portion of the distributed assets will be considered a “contribution” made to a retirement compensation arrangement (or the subject property of an RCA for the purposes s. 207.6(1) respecting the SERP Obligations assumed by Parent. ...

12 April 2018 External T.I. 2016-0640651E5 F - Swiss Pension -- summary under Subparagraph 56(1)(a)(i)

CRA considered that, based on its brief description, this policy likely qualified as a “superannuation or pension fund or plan.” ...

16 May 2018 IFA Roundtable Q. 3, 2018-0749171C6 - Interaction s.91(5) s.93.1(2)(d)(i) -- summary under Subsection 5900(3)

CRA considered this to be the appropriate result: there would have been the same $300 loss had Canco directly owned FA ($3,000 dividend- $3,000 s. 113(1) deduction- $300 interest expense). ...

16 May 2018 IFA Roundtable Q. 5, 2018-0745501C6 - Meaning of “merged or combined” in 40(3.5)(c)(i) -- summary under Subparagraph 40(3.5)(c)(i)

CRA indicated that it considered the phrase “merged or combined” in s. 40(3.5)(c)(i) as encompassing a winding-up or liquidation. ...

16 May 2018 IFA Roundtable Q. 7, 2018-0750261C6 -- summary under Subsection 39(2)

CRA referenced Consolidated Glass as indicating that the concept of a sustained loss is one of absolute and irrevocable finality, and that foreign exchange gains or losses respecting a debt obligation are considered to realized or sustained only on the settlement or extinguishment of the debt, i.e., on their repayment or legal novation or legal rescission and substitution, and would also result in the creditor realizing a corresponding foreign exchange gain or loss. ...

27 February 2018 Internal T.I. 2017-0682631I7 - Subsection 15(2.6) - Series of Loans -- summary under Subsection 15(2.6)

The only question posed was whether the daily cash sweeps were to be considered to be a series of loans or other transactions and repayments. ...

8 May 2018 CALU Roundtable Q. 6, 2018-0745871C6 - Tax on Split Income -- summary under Subparagraph (a)(i)

., selling life insurance or providing investment products) would be considered to be engaged in the provision of services? ...

1 February 2018 Internal T.I. 2016-0671921I7 - R&D Services - 95(2)(b) vs 247(2) & 95(3)(b), (d) -- summary under Paragraph 95(3)(d)

After finding that s. 95(2)(b) applied to the R&D Services provided to Canco, the Directorate rejected Canco’s argument that the R&D Services provided to Canco should be considered to be services performed as part of the manufacturing or processing of property, and as such subject to the exception provided in s. 95(2)(d), stating: [T]he R&D Services would not qualify as manufacturing or processing activities. ...

1 February 2018 Internal T.I. 2016-0671921I7 - R&D Services - 95(2)(b) vs 247(2) & 95(3)(b), (d) -- summary under Paragraph 95(3)(b)

After finding that s. 95(2)(b) applied to the R&D Services provided to Canco, the Directorate rejected Canco’s argument that the R&D Services provided to Canco should be considered to be services performed in connection with the sale of goods under s. 95(3)(b), stating: [T]he phrase “services performed in connection with the (...) sale of goods” is limited to services that are directly related to the sales function …. ...

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