no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan
Submitted by narmstrong on Thu, 01/06/2022 - 03:21
no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan
S. 56(1)(a) generally requires the recognition of an amount received as or in satisfaction of a pension benefit. A portion of a multi-employer US...
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no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan
no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan
the transfer of a portion of the assets and beneficiaries from an old to a new US pension plan did not result in taxable income under the IRC
183
Principal Issues: Whether a proposed transfer of assets and liabilities from a US 401(a) pension plan to another US 401(a) pension plan in respect of certain Canadian participants would be taxable to the Canadian participants pursuant to paragraph 6(1)(g) or subparagraph 56(1)(a)(i)?
Position: No.
Reasons: The Canadian participants will not receive or constructively receive any amounts as a result of the transfer.
Submitted by narmstrong on Fri, 01/07/2022 - 00:37
the granting of an emphyteusis is a part disposition of property rather than a lease
In 2013-0487791E5 F, CRA reversed its position in 2012-0472101E5 F and indicated that it now considered that the entering into of an emphyteutic...
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Principal Issues: Est-ce que la position énoncée dans l’interprétation technique 2013-0487791E5 représente la position de l’Agence du revenu du Canada? / Whether the position expressed in technical interpretation 2013-0487791E5 represent the position of the Canada Revenue Agency.
