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Income Tax Act- Section 86.1- Subsection 86.1(2)- Paragraph 86.1(2)(b) distribution did not qualify because distributed shares were not pre-owned by Mexican distributor Income Tax Act- Section 52- Subsection 52(2) distributed shares had ACB equal to the s. 90 inclusion of their FMV 28 November 2003 External T.I. 2003-0046025 F- CONVENTION DE RETRAITE DEDUCTIONS Also released under document number 2003-00460250. ...

Treaties- Income Tax Conventions- Article 18 Belgian National Pensions Office was a Belgian government instrumentality for purposes of the former Art. 18(2) exemption 2003-11-28 19 November 2003 Internal T.I. 2003-0047687 F- Interest Calculation T/P Adjustment RQST Also released under document number 2003-00476870. ...

Treaties- Income Tax Conventions- Article 18 degree of exemption for social security pension payments from Germany, Belgium or France 2 October 2003 External T.I. 2003-0033415 F- FRAIS D'ACCES INTERNET Also released under document number 2003-00334150. ...

Income Tax Act- Section 74.1- Subsection 74.1(2) s. 74.1(2) applies irrespective of child’s physical or mental condition 15 September 2003 External T.I. 2003-0033405 F- CONVENTION DE RETRAITE INTERETS COURUS Also released under document number 2003-00334050. ...

Summary of 17 May 2023 IFA Roundtable, Q.6 under Treaties – Income Tax Conventions – Art. 4. ...

Treaties- Income Tax Conventions- Article 15 exemption in Art. 15 of US Treaty unavailable where Canadian employee seconded to US affiliate, which reimburses for his payroll 24 March 2003 Internal T.I. 2002-0177587 F- XXXXXXXXXX EN CONSIGNATION PERTE Also released under document number 2002-01775870. ...

Income Tax Act- Section 39- Subsection 39(1)- Paragraph 39(1)(c)- Subparagraph 39(1)(c)(iii) usual s. 50(1)(b)(i) and SBC qualification rules applied to shares of a cooperative corporation that became bankrupt 11 December 2002 Internal T.I. 2002-0173007 F- Observation aux commentaires (OCDE) Treaties- Income Tax Conventions- Article 12 Canada’s withdrawal of its observation on Art. 12 on March 28, 2002 was prospective, and did not affect its right to impose withholding tax on payments for use of a secret process prior to that date 2002-12-06 16 December 2002 External T.I. 2002-0138195 F- ALLOCATION POUR FRAIS DE DEPLACEMENT Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(vii.1) travel allowance for travel 40% of the employment days between home and a more remote employer situs was for personal travel Income Tax Act- Section 81- Subsection 81(3.1) amalgamation of 2 part-time employers ended the s. 81(3.1) exclusion so that travel allowance was for personal travel 17 December 2002 External T.I. 2002-0158165 F- REPAS DE FETE OFFERTS PAR L'EMPLOYEUR Income Tax Act- Section 67.1- Subsection 67.1(2)- Paragraph 67.1(2)(f) monthly restaurant event for only those employees whose birthday month it was would not qualify/ restaurant implicitly the employer’s place of business 20 December 2002 External T.I. 2002-0159365 F- REMUNERATION NON MONETAIRE Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) no source deduction or remittance obligations where all remuneration is non-monetary ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2023-12-20 6 November 2019 Internal T.I. 2019-0798021I7 F- Assessment under 159(3) Income Tax Act- Section 159- Subsection 159(3) trustees were liable under s. 159(3) notwithstanding having obtained a post-distribution s. 159(2) certificate 2023-11-29 2023 Ruling 2022-0923451R3 F- 55(3)(a) internal reorganization Income Tax Act- Section 55- Subsection 55(3)- Paragraph 55(3)(a) indirect spin-off of subsidiary groups to 2 transferee corporations held by holding companies for 2 brothers while such transferee corporations are controlled by father with special voting shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) proration of DSI on s. 55(3)(a) spin-offs based on the net cost amount of the property spun off 2002-06-21 9 July 2002 External T.I. 2002-0147985 F- ACTIONS PRIVILEGIEES CONVERTIBLES Income Tax Act- Section 7- Subsection 7(1.5) no disposition for purposes of s. 7(1.5) when employee’s preferred shares converted to common shares Income Tax Act- Section 7- Subsection 7(1)- Paragraph 7(1)(a) s. 7(1)(a) benefit when employee’s convertible preferred shares converted to common shares 5 July 2002 External T.I. 2002-0121115 F- CREDIT-BAIL Income Tax Act- Section 13- Subsection 13(21)- Depreciable Property lessor rather than lessee under a financing lease was entitled to CCA 11 July 2002 External T.I. 2002-0126795 F- RESSOURCES INTERMEDIAIRES REVENU EX Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(h) contributions paid to a Quebec intermediate resource have been treated as means-based assistance 11 July 2002 External T.I. 2002-0131085 F- ASSURANCE INVALIDITE Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(f) employer can pay an employee additional remuneration equal to the premiums payable by the employee under employee-pay-all plan 8 July 2002 External T.I. 2002-0131835 F- Investissements détenus à l'étranger Treaties- Income Tax Conventions- Article 22 Canada could tax income and gains of a Canadian resident from a French life insurance policy 8 July 2002 External T.I. 2002-0136615 F- Par. 250(5)- Déclaration de revenus Income Tax Act- Section 250- Subsection 250(5) individual deemed to be non-resident by s. 250(5) is not required to report world income ...

Summary of 13 October 2023 Internal T.I. 2019-0819351I7 under Treaties – Income Tax Conventions – Art. 9. ...

Summaries of 2023 Ruling 2022-0958521R3 under s. 87(8.2) and Treaties – Income Tax Conventions – Art. 13. ...