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4 October 2002 Internal T.I. 2001-010564A F- PENSION ALIMENTAIRE-ARRERAGES-- summary under Paragraph 60(b) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(b) lump sum payment in settlement of periodic support payments in arrears is an amount payable on a periodic basis In finding that a lump-sum payment to cover support-payment arrears could be considered as an amount payable on a periodic basis, even though it was less than the amount initially anticipated, the Directorate stated: [G]enerally, a lump sum paid in a taxation year is regarded as qualifying as a periodic payment where it can be identified as being the payment of amounts payable periodically that were due after the date of the order or agreement and had fallen into arrears. ...

6 March 1995 Internal T.I. 9409947- WINDING-UP OF A FOREIGN AFFILIATE-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition no disposition of shares of UK sub on interim liquidation distributions In finding that the shares of a UK subsidiary were disposed of when the shares were cancelled on completion of voluntary dissolution proceedings CRA stated: [I]t would be inconsistent with the spirit of the law to consider the disposition of the shares of a controlled foreign affiliate to have occurred as soon as the shareholders become eligible for partial proceeds of disposition on a wind-up because not only is it impossible to compute the full amount of the gain at that time, any FAPI that may be earned by the affiliate subsequent to that time presumably could not be considered to be in respect of shares owned by the taxpayer for the purposes of subsection 91.... ...

However, this position relied in part on the analogous activities of a commercial printer (including publisher) which, in IT-145R, para. 42, were considered to constitute manufacturing or processing. ...

After noting that the phrase “an employer who participates in the plan” in s. 147.2(2)(a)(vi) was a “grammatical variation” of the defined term, CRA indicated that it considers that for the purpose of s. 147.2(2)(a)(vi) and other uses of the concept of a participating employer, an employer is considered to be a participating employer even if it has been dissolved or otherwise ceased to exist. ...

Such amounts “could be considered a qualifying amount.” ...

7 December 2020 Internal T.I. 2020-0867851I7- Canada Emergency Student Benefit-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 CRA indicates no Indian Act exemption for CESB benefits Regarding the taxability of the Canada emergency student benefit (CESB) received by a First Nation individual, CRA indicated that it could not be exempted under s. 87 as it “is not considered to be situated on a reserve as there are insufficient factors connecting this income to a reserve” (even if the “the recipient is a First Nation individual residing on a reserve”) and it instead “is available to all Canadians who qualify and [is] paid from general government funds.” ...

8 November 2022 Internal T.I. 2022-0941391I7- (Re)determination of section 125.7 applications-- summary under Prescribed Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Prescribed filing of multiple applications on an RP account basis could be authorized by the Minister After noting that the instructions provided by CRA both on the application for the CEWS or CRHP benefit and the CRA website indicated that a separate application must be filed for each RP account, the Directorate indicated that such separate applications aggregating to an overall deemed overpayment for a qualifying period should be considered to constitute an application for the qualifying period in the prescribed form and manner as required by para. ...

8 November 2022 Internal T.I. 2022-0941391I7- (Re)determination of section 125.7 applications-- summary under Paragraph 125.7(5)(a) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(5)- Paragraph 125.7(5)(a) movements of upward or downward adjustments between various RP accounts by redeterminations subject to s. 125.7(5)(a) limitation After noting that the instructions provided by CRA both on the application for the CEWS or CRHP benefit and the CRA website indicated that a separate application must be filed for each RP account, the Directorate indicated that such separate applications aggregating to an overall deemed overpayment for a qualifying period should be considered to constitute an application for the qualifying period in the prescribed form and manner as required by para. ...

However, there was no liability under s. 116(5) to the Canadian corporation that had issued the options as it should not be considered to have acquired the options from the employee and, therefore, had no cost therefor. ...

After noting that a limited partnership with a sole general partner is generally considered to be controlled by that general partner, CRA indicated that C Ltd. thus controlled Opco, and that the “ultimate control” of Opco, as described in Parthenon, was held by A Ltd. ...