Income Tax Severed Letters - 2025-10-15

Ruling

2025 Ruling 2022-0943251R3 - Application of 108(2)(b)(iii) and (iv)

Unedited CRA Tags
108(2)(b)
Summary Under
Tax Topics - Income Tax Act - Section 108 - Subsection 108(2) - Paragraph 108(2)(b) - Subparagraph 108(2)(b)(iv)
s. 108(2)(b) unit trust using a subsidiary LP to engage in hedging to offset hedging by an underlying fund investment, while avoiding net hedging gains for s. 108(2)(b)(iv) purposes

Principal Issues: 1) Whether units of a particular ETF would be considered a marketable security for purposes of clause 108(2)(b)(iii)(E)? 2) Whether income is computed on a net basis for purposes of subparagraph 108(2)(b)(iv) where the relevant income sources are held in a tiered partnership structure.

Position: 1) The particular units would qualify. 2) Opinion provided.

Reasons: 1) The law.

Technical Interpretation - External

18 June 2025 External T.I. 2025-1065871E5 - Behaviour Analysts in Ontario

Unedited CRA Tags
118.4, 118.4(2)

Principal Issues: Whether Behaviour Analysts in Ontario are authorized medical practitioners for purposes of the medical expense tax credit.

Position: Yes.

Reasons: There is specific legislation that governs the practice of Behavioural Analysts in Ontario.