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29 January 2015 Internal T.I. 2014-0544651I7- Section 85 transfer of Swap Contracts-- summary under Inventory Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Inventory swap contract treated as inventory CRA found that cross-currency swaps with accrued gains, which for redacted reasons were considered to be held on income rather than capital account, qualified as "inventory" under the broad s. 248(1) definition, so that they could be transferred on a rollover basis into subsidiaries under s. 85(1). ...

1 September 2015 Internal T.I. 2013-0507381I7- Transfer pricing adjustments and gross revenue-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) [s. 247(2) increases to gross revenues] CRA considered that an upward adjustment to a Canadian resident’s sales proceeds – but not a downward adjustment to its purchase price for goods – increased its gross revenue for provincial income allocation purposes. ...

1 September 2015 Internal T.I. 2013-0507381I7- Transfer pricing adjustments and gross revenue-- summary under Gross Revenue Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Gross Revenue sales (but not purchases) transfer pricing adjustments to gross revenue CRA considered that an upward adjustment under s. 247(2) to a Canadian resident’s sales proceeds – but not a downward adjustment to its purchase price for goods – increased its gross revenue for provincial income allocation purposes. ...

24 December 2015 Internal T.I. 2014-0560831I7- International shipping-- summary under International Shipping Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- International Shipping lease includes time charter CRA indicated that the “international shipping” definition, which “introduced what may be considered to be a new requirement that the ships must be ‘owned or leased’ by the relevant taxpayer” can be satisfied by the taxpayer being the charterer under a time charter (provided it had “commercial management” of the ship, i.e., “the ship owner is operating the ship under the Taxpayer’s direction.”) ...

22 March 2016 Internal T.I. 2013-0506561I7- Property acquired on a return of capital-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base FMV cost of contributed or distributed property CRA considered that property contributed for no consideration to a corporation by its shareholder, or received by a Canadian corporate shareholder from its wholly-owned foreign affiliate on a return of capital (or other upstream transfer), generally will have a cost to the transferee equal to the property’s fair market value. ...

12 October 2016 Internal T.I. 2016-0637781I7- Employee loan or debt extinguished or settled-- summary under Paragraph 80(2)(a) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(2)- Paragraph 80(2)(a) writing-off debt was its settlement Respecting the situation where an employee debt became statute-barred, and the employer then wrote it off because it was thus no longer legally collectible, CRA considered this writing-off to be sufficient to trigger s. 6(15). ...

4 April 1997 Internal T.I. 9638817- ACQUISITION OF VACANT LAND-- summary under Subsection 18(2) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(2) Where the owner of a motel purchases a city-owned lot adjacent to the motel property in an effort to prevent it from being developed in a manner which would be detrimental to the motel business, that lot (if kept vacant) would not be considered to be used in the business of the owner of the motel. ...

20 February 1997 Internal T.I. 9637077- FISCAL PERIOD- SIMILAR SERVICES-- summary under Old 34.2 Summary Under Tax Topics- Income Tax Act- Section 34.2- Old 34.2 "It is unlikely that the services of a financial planner would be considered to be similar to those of an accountant. ...

Repairs or Running Expense replacing vines or trees Replacement plantings of grape wines would be considered to be deductible expenses, whereas replacing one type of fruit by another (e.g., an apple tree with a cherry tree) would not be on income account. ...

26 October 1998 Internal T.I. 9803947- REDEMPTION OF SHARES-- summary under Subsection 84(3) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(3) deemed dividend on M2M shaes reduced by deemed dividend Where shares held by a financial institution are redeemed, s. 84(3) will be considered to take precedence over s. 142.5(1), and s. 248(28) will apply to allow the financial institution to reduce its proceeds of disposition by the amount of the deemed dividend. ...