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9 March 2016 Internal T.I. 2015-0612501I7- ITA 261(21) anti-avoidance-- summary under Tax Reporting Currency Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(1)- Tax Reporting Currency non-resident parent would have Canadian dollar as tax reporting currency CRA considered that s. 261(21) did not apply to deny an FX loss sustained by a Canadian subsidiary (“Holdco”) of a non-resident parent (“Parent”) on hedging agreements it entered into with Parent to hedge its FX exposure on a U.S. dollar loan it had made to a Canadian subsidiary of Holdco which, unlike Holdco, had the U.S. dollar as its reporting currency, given that any of Parent's Canadian tax results would have been determined in Canadian dollars. ...

20 July 2011 Internal T.I. 2011-0397961I7- Aggregate Investment Income-- summary under Aggregate Investment Income Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4)- Aggregate Investment Income s. 94.1(1) income was income from property CRA indicated that an amount included in income of a corporation pursuant to s. 94.1(1) would be considered to be from a source that is a property (and, thus, would be included in the definition of "aggregate investment income" in s. 129(4)) notwithstanding that, unlike the income inclusion under s. 91(1) regarding FAPI, such income was not deemed to be in respect of a share owned by the taxpayer of the capital stock of a foreign affiliate of the taxpayer. ...

The Directorate stated that, in accordance with ITTN No. 30, “any remuneration paid to a partner for work performed in the course of partnership business may properly be considered a distribution of income or a withdrawal of capital and is not deductible in computing a partnership's income,” and that here, the amount was a non-deductible capital withdrawal. ...

., prior to the amendment of s. 248(3)), the usufructuary was considered to continue as the beneficial owner, including for the purposes of applying the principal residence exemption on his death in 2007. ...

., that “could be considered as a payment in respect of the right to purchase the property in the future.” ...

2 August 2005 Internal T.I. 2005-0135701I7 F- Exonération- Indien inscrit-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 being on standby does not constitute the performance of duties of employment In rejecting a claim that in the context of reporting to work at an office off the reserve for 37.5 hours per week but also being required to be on standby on the reserve, the Indian claimant should be considered to be performing his duties more than 50% on the reserve, the Directorate stated: The mere fact of being available under an employment contract does not, in itself, constitute the performance of employment duties on a reserve or elsewhere. ...

Headquarters considered that the interest on the replacement notes was not deductible because it did not replace borrowed money nor were they used to acquire property. ...

[O]nly in rare and unique situations would the word 'rent' be considered to mean 'royalty'". ...

14 July 1998 Internal T.I. 9808476- BROADCASTER ACQUIRING EQUITY INTEREST-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition A Canadian producer would be considered to have disposed of a portion of its beneficial interest in a television production when it entered into a licence agreement with a broadcaster under which in consideration for a licence fee it agreed to pay the broadcaster 10% of all revenues derived from exploitation of the episodes, merchandise and ancillary products throughout the world in perpetuity with the broadcaster, in addition to receiving broadcasting rights, receiving other rights including ICRS rights, merchandising rights and development rights but without any transfer of copyright ownership. ...

Accordingly, where a fresh notice of reassessment is issued to reflect changes in a taxpayer's non-capital losses under Part I, with the amount shown for Part I.3 tax being unchanged, there will not be considered to have been a new assessment of Part I.3 tax. ...