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Bundle Date Translated severed letter Summaries under Summary descriptor 2022-11-09 18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T Income Tax Regulations- Regulation 1102- Subsection 1102(5)- Paragraph 1102(5)(a)- Subparagraph 1102(5)(a)(iii) rendering of an empty shell suitable for manufacturing constituted substantially changing its nature Income Tax Regulations- Schedules- Schedule II- Class 8- Paragraph 8(b) property does not satisfy the “solely” test in Class 8(b) where it was necessary for the proper functioning of the building Income Tax Act- Section 13- Subsection 13(21)- Undepreciated Capital Cost- A cost of installing property part of that property’s cost Income Tax Regulations- Regulation 1102- Subsection 1102(4) to be improvements or alterations to leasehold interest, property acquisitions must be assimilated to landlord’s property General Concepts- Ownership leasehold improvements are assimilated to the landlord’s property unless the lease specifies otherwise Income Tax Regulations- Regulation 1102- Subsection 1102(5) building shell was a building or structure/ addition refers to extension of structure 2021 Ruling 2021-0916821R3 F- Continuance corporation from CBCA to Co-operative Income Tax Act- Section 86- Subsection 86(1) application of s. 86 reorganization rule to a continuance from the CBCA to a Co-operatives Act Income Tax Act- Section 248- Subsection 248(1)- Disposition continuance from the CBCA to a Co-operatives Act did not entail disposition of assets, but s. 86 applied at the shareholder level 2004-04-30 28 April 2004 Internal T.I. 2004-0071331I7 F- Régime d'investissement coopératif du Québec Income Tax Act- Section 53- Subsection 53(2)- Paragraph 53(2)(k) listed assistance does not include a deduction from taxable income 2004-04-23 15 April 2004 Internal T.I. 2004-0062451I7 F- Résidence principale Income Tax Act- Section 54- Principal Residence- Paragraph (c) no need to file form for principal residence portion of disposed-of property if it was fully exempted 2004-01-23 14 January 2004 External T.I. 2003-0046131E5 F- Convention de retraite- dépositaire Income Tax Act- Section 207.6- Subsection 207.6(2) employer is deemed custodian under s. 207.6(2) Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement life insurance company can be a custodian 2004-01-16 9 January 2004 External T.I. 2003-0049195 F- Winding Up or a Contractor Subco Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(e.1) s. 88(1)(e.1) would permit parent to step into shoes of sub re s. 12(1)(a) inclusion and s. 20(1)(m) reserveIdentical to 2003-00491950 9 January 2004 External T.I. 2003-0047341E5 F- Coût indiqué- Biens étrangers Income Tax Act- Section 54- Adjusted Cost Base distribution of shares out of MFT and exchange for new MFT units would reset the ACB/ cost amount 9 January 2004 External T.I. 2003-00491950 F- Winding Up or a Contractor Subco Income Tax Act- Section 9- Timing exclusion of contract holdbacks and unapproved invoices from construction contractor’s income is unaffected on s. 88(1) wind-up and flows through to parent Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) deferred revenue of construction contractor would not be triggered on its s. 88(1) wind-up and parent would be put to claiming any available new s. 20(1)(m) reserve ...

Income Tax Act- Section 40- Subsection 40(3.4) non-application of s. 40(3.4) where taxpayer acquires then immediately disposes of an additional block/ application of formula where it partially dips into existing block 4 November 2003 External T.I. 2003-0042295 F- CONVENTION DE RETRAITE REVENU D'INTERET Also released under document number 2003-00422950. ...

Income Tax Act- Section 6- Subsection 6(16)- Paragraph 6(16)(a) per-kilometre rates published by Finance could be used for reasonableness purposes 16 October 2003 External T.I. 2003-0038315 F- CONVENTION DE RETRAITE Also released under document number 2003-00383150. ...

Income Tax Act- Section 118- Subsection 118(1)- Paragraph 118(1)(b) young child could not claim credit for mother 10 October 2003 External T.I. 2003-0037145 F- CONVENTION DE RETRAITE Also released under document number 2003-00371450. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2023-09-06 10 February 2022 External T.I. 2019-0819651E5 F- Pension from China Treaties- Income Tax Conventions- Article 19 pension from China paid to former civil servant now resident in Canada was not exempted under Art. 18 of the Canada-China Treaty 2003-10-03 30 September 2003 External T.I. 2003-0035725 F- MONTANT RELATIF AUX ETUDES Also released under document number 2003-00357250. ...

The King, 2023 TCC 167 under s. 212(2), Treaties – Income Tax Conventions – Art. 10, s. 245(1) – tax benefit, s. 245(4). ...

I tax 27 February 2002 External T.I. 2001-0109675 F- Période admissible et vacance Income Tax Act- Section 122.3- Subsection 122.3(1) period of employment abroad does not include vacation days that could have been taken abroad, but were not 18 March 2002 External T.I. 2002-0120065 F- Avoir fiscal français- 20(11) Income Tax Act- Section 90- Subsection 90(1) French avoir fiscal did not reduce the dividend from a French company required to be included in the resident individual shareholder’s income Treaties- Income Tax Conventions- Article 10 subsequent refund to Canadian shareholder of French avoir fiscal treated as a dividend payment for dividend withholding purposes 2 May 2002 Internal T.I. 2002-0122607 F- BIENS A USAGE PERSONNEL Income Tax Regulations- Regulation 1102- Regulation 1102(2) effective severance for ITA purposes of land and building by Reg. 1102(2) does not apply to personal-use property Income Tax Act- Section 248- Subsection 248(1)- Property where Reg. 1102(2) does not apply, land and building are a single property generating a single gain ...

Summary of Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation [2024] FCAFC 29 under Treaties – Income Tax Conventions – Art. 9. ...

Summary of Revenue & Customs v Burlington Loan Management DAC [2024] UKUT 152 under Treaties – Income Tax Conventions – Art. 12. ...

Profit- Patents and Know-How the consequences of a sale of IP by a partnership for the benefit of a university and its researchers might be addressed in a ruling 2000-11-10 25 October 2000 External T.I. 2000-0017065 F- CONVENTION DE RETRAITE ET ASSURANCE Income Tax Act- Section 207.6- Subsection 207.6(2) no Pt. ...