Income Tax Severed Letters - 2015-09-30

Technical Interpretation - External

9 September 2015 External T.I. 2014-0563611E5 F - Call Centre - Location of the services performed

CRA Tags
ITR 105(1), 153(1)
non-resident call centre not rendering services in Canada

Principal Issues: Whether subsection 105(1) of the Regulations applies to a payment made to a non-resident in respect of call centre services performed outside Canada?

Position: Question of fact, but generally no.

Reasons: Telecommunication system appears to be used as a means of transmission

10 August 2015 External T.I. 2015-0602751E5 - Capital gains deduction and section 84.1

CRA Tags
84.1, 110.6
statement of purpose and simple examples of s. 84.1 application

Principal Issues: Tax policy issue regarding the potential application of section 84.1 in the context of a proposed transaction

Position: General comments provided.

Reasons: Tax policy issue.