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23 November 2007 Internal T.I. 2007-0258051I7 F- REÉR- Hypothèque légale-- summary under Subparagraph 146(2)(c.3)(ii) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(2)- Paragraph 146(2)(c.3)- Subparagraph 146(2)(c.3)(ii) tax debtor can pledge his RRSP to CRA without triggering an income inclusion under s. 146(12) The Directorate indicated that a tax debtor could provide a hypothec of his interest in his RRSP to CRA in order to secure a tax debt without the RRSP being considered to have breached the condition in s. 146(2)(c.3)(ii), so that there would be no inclusion of the FMV of the RRSP in the annuitant’s income under s. 146(12). ...

In responding “yes,” the Directorate stated: According to … IT-113R4, paragraph 12, pursuant to the definitions of "employee" and "office" in subsection 248(1), corporate directors are considered to be employees. ...

It is our view that a therapeutic riding school cannot be considered an "other place" for the purposes of paragraph 118.2(2)(e) since it is not a place sufficiently similar to a school or institution. ...

CRA considered it unnecessary to answer this question as, even if the relevant agreement for purposes of the March 21, 2013 cut-off was the subcontracting agreement, the expenses would qualify under para. ...

18 May 2006 Internal T.I. 2006-0182321I7 F- Déduction des intérêts-- summary under Subparagraph 20(1)(c)(ii) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(ii) refinancing dividend-payment notes with interest-bearing shareholder loans did not cure the interest-deductibility problem In confirming that interest on notes issued to pay dividends was non-deductible, as was interest on loans received from the shareholders to pay off the notes, the Directorate stated: [I]t is the legal relationship between the parties that must be considered. ...

28 August 2006 Internal T.I. 2006-0171141I7 F- Régime d'assurance collective contre la maladie-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) a qualifying plan can be implemented by individual disability insurance policies taken out for all management employees if there is a similar premium sharing arrangement for all Could the employer premiums paid for individual disability insurance policies taken out in respect of all the management employees be considered to be premiums paid respecting a group sickness or accident insurance plan? ...

., a distributor) could be considered to have acquired all beneficial ownership rights in the copyright in a production, if the production company grants to that third party all of the revenues from the distribution or the right to distribute or otherwise exploit the film in markets representing most or all of the exploitable value of the film. ...

In finding that each Corporation had a personal services business (PSB), the Directorate considered that X controlled the work of the individual shareholders and that the Corporations’ operations were integrated into the business of X. ...

27 October 2017 Internal T.I. 2017-0694231I7- Subsection 247(2), surplus, and FAPI-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1)- Earnings- Paragraph (a) surplus could be adjusted by transfer-pricing adjustment The Directorate considered that where there was a s. 247(2) transfer pricing adjustment to increase Canco’s income as a result of having undercharged for goods or services provided to a non-resident subsidiary (CFA), s. 247(2) could not also be applied to reduce the exempt surplus or foreign accrual property income of CFA in respect of Canco. ...

CRA considered Foreign Sub to be the “taxpayer” and effectively treated Finco as the deemed corporation resident in Canada, so that Finco was liable under s. 215(1) for failure to “withhold” and remit Part XIII tax on the imputed benefit. ...