Words and Phrases - "parent"

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28
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12
10
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17 July 2012 Internal T.I. 2012-0454701I7 F - Arrière-arrière-grand-père

parent in s. 110.6 context includes great-grandparent but not great-great-grandparent

In finding that for purposes of s. 110.6(1) the “parent” of a taxpayer holding a now-inactive farm property included the great-grandfather of the taxpayer but not his great-great-grandfather of the taxpayer, CRA noted that the s. 110.6(1) definition of “child” referred to the definition of “child” in s. 70(1), and then stated:

In interpreting the meaning of the term "parent" and in determining whether that term may include a reference to the term "great-great-grandparent", subsection 70(10) should be read in conjunction with subsection 252(2).

However, under paragraph 252(2)(a), the reference to "parent" includes a person whose child the taxpayer is. Since subsection 70(10) equates the word "child" with "a child of the taxpayer’s child” and “a child of the taxpayer’s child’s child” and subsections 110.6(1) and 110.6(1.3) refer to the word "parent", all references to the "parent" of a taxpayer would be, by analogy, a reference to the "grandparent" and "great-grandparent" of the taxpayer.

It would be impossible for us to extend this definition more broadly to include "great-great-grandparent" as this would be contrary to the intention of the legislator.

Words and Phrases
parent
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Share of the Capital Stock of a Family Farm or Fishing Corporation - Paragraph (a) - Subparagraph (a)(iii) farm use by great-great-grandparent did not qualify the property, cf. great-grandparent 217