Income Tax Severed Letters - 2017-02-22

Ruling

2015 Ruling 2015-0573321R3 - Qualifying Environmental Trust

Unedited CRA Tags
ss. 211.6, 20(1)(ss)

Principal Issues: 1. Whether the proposed Trust meets the definition of a “qualifying environmental trust” in subsection 211.6(1) of the Act. 2. Whether contributions made by the taxpayer to the Trust will be deductible in computing the taxpayer's income pursuant to paragraph 20(1)(ss) of the Act. 3. Whether Government of Canada bonds and Treasury Bills will be a “prohibited investment” of the Trust as that term is defined in subsection 211.6(1).

Position: 1. Yes 2. Yes provided that the Trust is a QET at the time of the contribution. 3. No.

Reasons: Legislative text.

2015 Ruling 2015-0619271R3 - Qualifying Environmental Trusts for Pipelines

Unedited CRA Tags
211.6, 20(1)(ss); 107.3

Principal Issues: 1. Whether the proposed Trust meets the definition of a “qualifying environmental trust” in subsection 211.6(1) of the Act.
2. Whether contributions made by the taxpayer to the Trust will be deductible in computing taxpayer’s income pursuant to paragraph 20(1)(ss) of the Act. 3. Whether Government of Canada bonds and Treasury Bills will be a “prohibited investment” of the Trust as that term is defined in subsection 211.6(1).

Position: 1. Yes; 2. Yes, provided that the Trust is a QET at the time of the contribution. 3. No.

Reasons: Legislative text.

2015 Ruling 2015-0572761R3 - Qualifying Environmental Trusts for Pipelines

Unedited CRA Tags
211.6, 20(1)(ss)

Principal Issues: 1. Whether the proposed Trust meets the definition of a “qualifying environmental trust” in subsection 211.6(1) of the Act.
2. Whether contributions made by the taxpayers to the Trust will be deductible in computing taxpayers' income pursuant to paragraph 20(1)(ss) of the Act. 3. Whether ETFs (Exchange Traded Funds) organized as trusts and traded on a designated stock exchange will be a “prohibited investment” of the QET as that term is defined in subsection 211.6(1). 4. Whether Government of Canada bonds and Treasury Bills will be a “prohibited investment” of the Trust as that term is defined in subsection 211.6(1).

Position: 1. Yes; 2. Yes, provided that the Trust is a QET at the time of the contribution; 3. No.

Reasons: Legislative text.

Technical Interpretation - External

28 December 2016 External T.I. 2016-0659651E5 - Indian Employment Income and the Proration Rule

Unedited CRA Tags
81(1)(a)

Principal Issues: Clarification of the Proration Rule

Position: General comments provided

Reasons: See below