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Convention). CAHPL’s appeal was dismissed. In his concurring reasons, Allsop CJ stated respecting the assimilated Art. 9 rule: [W]ere CAHPL seeking to borrow for five years on an unsecured basis with no financial or operational covenants from an independent lender, in order to act rationally and commercially and conformably with the interests of the Chevron group to obtain external funding at the lowest possible cost consistently with any relevant operational considerations, it would do so with Chevron providing a parent company guarantee, if such were available. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2014-07-02 3 June 2014 External T.I. 2013-0503511E5 F- Discretionary Dividend Shares Income Tax Act- 101-110- Section 110.6- Subsection 110.6(7) discretionary dividend prefs used to extract excess cash 14 April 2014 Internal T.I. 2013-0516151I7 F- Article XIII(4) of the Canada-XXXXXXXXXX Convention Treaties- Articles of Treaties- Article 13 partnerships holding Quebec real estate were transparent 2014-06-25 23 May 2014 External T.I. 2014-0518921E5 F- Calcul de l'élément A du MCIA Income Tax Act- Section 14- Subsection 14(5)- Cumulative Eligible Capital A.1 of A reduction does not apply in year of sale 27 May 2014 Internal T.I. 2014-0521631I7 F- Déductibilité d'un alcoomètre Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose not necessary to show that expenditure generated income- and potential deduction where 20% personal use Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) full personal element if the expense would have otherwise been paid by the employee 3 June 2014 External T.I. 2014-0518911E5 F- Grand routier / long-haul truck Income Tax Act- Section 67.1- Subsection 67.1(5)- Long-haul truck weight reference is to loaded weight determined by manufacturer 2014-06-18 29 May 2014 External T.I. 2014-0520851E5 F- Deferred Salary Leave Plan Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(i) terms cannot provide for voluntary withdrawal of employee except where hardship Income Tax Regulations- Regulation 6801- Paragraph 6801(a)- Subparagraph 6801(a)(iv)- Clause 6801(a)(iv)(B) no requirement for employer to provide a return on the deferred amounts ...

Summaries of Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)," Bulletin for International Taxation, November 2017, p. 607 under Treaties – MLI – Art. 20, Art. 19 and Art. 28(2). ...

But there was the Treaty, whose Royalty Article was similar to the OECD Model, the Commentary on which stated that that payments made in consideration for obtaining the exclusive distribution rights of a product in a given territory do not constitute royalties within the meaning of the Model Tax Convention as they are not made in consideration for the use of, or the right to use, an element of property included in the Royalty definition. ...

The Queen, 2018 TCC 142 under s. 2(1), s. 128.1(1)(c) and Treaties- Income Tax Conventions- Art. 4. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2013-03-13 14 December 2012 External T.I. 2012-0436981E5 F- Ristournes de coopératives de travailleurs Income Tax Act- Section 135- Subsection 135(4)- Allocation in Proportion to Patronage distribution on winding-up of enhancement reserve does not qualify 19 December 2012 External T.I. 2012-0463581E5 F- Allocation pour l'usage d'un véhicule Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) travel to and from home where shifting clientele is in the performance of employment duties/Reg. 7306 rates presumptively reasonable 2013-03-06 19 December 2012 External T.I. 2012-0468511E5 F- GRIP addition for 2006 Income Tax Act- Section 89- Subsection 89(7)- Element A no adjustment made for dividend received from connected CCPC sold over 4 years before 2006 2013-02-27 30 January 2013 External T.I. 2012-0449621E5 F- Belgian pension Treaties- Income Tax Conventions- Article 18 Belgian social security payment received by Canadan resident must be included in the personal return, but with offsetting s 110(1)(f)(i) deduction claimed Income Tax Act- 101-110- Section 110- Subsection 110(1)- Paragraph 110(1)(f)- Subparagraph 110(1)(f)(i) Treaty-exempt receipt required to be reported, but with offsetting s 110(1)(f)(i) deduction 2013-02-20 13 February 2013 External T.I. 2013-0477151E5 F- Crédit d'impôt pour études Income Tax Act- Section 118.6- Subsection 118.6(2) given 2012 disruptions, months to be computed based on the original schedule 5 February 2013 External T.I. 2012-0465591E5 F- Form T5018 Income Tax Regulations- Regulation 238- Subsection 238(1) landscaping business could be construction ...

Summaries of 27 March 2018 External T.I. 2017-0715561E5 under s. 212(5) and Treaties – Income Tax Conventions – Art. 12. ...

Summary of Satyam Computer Services Limited v Commissioner of Taxation [2018] FCAFC 172 under Treaties – Income Tax Conventions – Art. 24. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2011-12-16 8 December 2011 External T.I. 2011-0427451E5 F- Statut de résidence fiscale Income Tax Act- Section 2- Subsection 2(1) Rulings Directorate does not determine residency 6 December 2011 External T.I. 2010-0384701E5 F- Décès contribuable- Immobilisation admissible Income Tax Act- Section 70- Subsection 70(5.1) application of s. 70(5.1) to bequest of goodwill General Concepts- Effective Date CRA policy of price adjustment clauses inapplicable where deferred sale price subsequently adjusted Income Tax Act- Section 152- Subsection 152(4.2) CRA policy for adjusting a statute-barred year for a reduction in the 5th year of staged-proceeds sale 15 November 2011 External T.I. 2011-0415881E5 F- Pension alimentaire pour enfants Treaties- Income Tax Conventions- Article 18 taxpayer not entitled to deduct child support payments upon becoming a non-resident 9 December 2011 External T.I. 2011-0429321E5 F- Changement d'usage Income Tax Act- Section 45- Subsection 45(1)- Paragraph 45(1)(a) FMV is measured at the time of change of use 21 November 2011 External T.I. 2011-0426481E5 F- Actions admissibles de petite entreprise Income Tax Act- 101-110- Section 110.6- Subsection 110.6(14)- Paragraph 110.6(14)(f)- Subparagraph 110.6(14)(f)(ii)- Clause 110.6(14)(f)(ii)(A) “substantially all” (meaning 90% or more) test satisfied even though only leasehold interest in real estate transferred 17 November 2011 External T.I. 2011-0414811E5 F- Frais médicaux- fins esthétiques Income Tax Act- Section 118.2- Subsection 118.2(2.1) qualifying breast surgery expenses ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2019-07-10 4 June 2019 Internal T.I. 2018-0783441I7 F- Sale of land by a resident of Hong Kong Treaties- Income Tax Conventions- Article 13 Canadian land was not Treaty-exempt even where it did not generate income 2011-11-25 7 November 2011 Internal T.I. 2011-0424641I7 F- Right to cut Christmas trees Income Tax Act- Section 13- Subsection 13(21)- Timber Resource Property right to cut Christmas trees was not a timber resource property Income Tax Regulations- Regulation 1100- Subsection 1100(1)- Paragraph 1100(1)(e) Christmas trees are not “timber” Income Tax Regulations- Schedules- Schedule II- Class 14 right to cut Christmas trees with 10-year term was a Class 14 property 7 October 2011 Roundtable, 2011-0411871C6 F- Employé constitué en société Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business PSB can have two spouses as incorporated employees 7 October 2011 Roundtable, 2011-0411841C6 F- Succession Income Tax Act- 101-110- Section 104- Subsection 104(1) estate could cease when assets converted to cash and liabilities settled 7 October 2011 Roundtable, 2011-0412091C6 F- Late Filed Paragraph 55(5)(f) Designation Income Tax Act- Section 55- Subsection 55(5)- Paragraph 55(5)(f) CRA practice to only treat excess of taxable dividend over safe income as subject to s. 55(2) 7 October 2011 Roundtable, 2011-0411891C6 F- Dépenses- EPSP- négociant en vente Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(p)- Sjubparagraph 18(1)(p)(iii) s. 18(1)(p)(iii) deduction limited to commission income Income Tax Act- Section 8- Subsection 8(13) home office of a PSP corporation’s employee could qualify ...