CRA has released the official version of the 2025 IFA Roundtable
14 August 2025 - 12:04am
Email this ContentThe table below provides links to the official versions of the May 28, 2025 IFA Roundtable items together with summaries of the CRA answers which we provided in the week following that conference.
| Topic | Descriptor | |
|---|---|---|
| 28 May 2025 IFA Roundtable Q. 1, 2025-1052641C6 - Digital Services Tax (DST) Act | Other Legislation/Constitution - Federal - Digital Services Tax Act - Section 45 | various issues re CRA administration |
| 28 May 2025 IFA Roundtable Q. 2, 2025-1052681C6 - Global Minimum Tax Act | Other Legislation/Constitution - Federal - Global Minimum Tax Act - Section 60 - Subsection 60(1) | affected taxpayers are expected to start registering for GMTA purposes in late 2025 |
| 28 May 2025 IFA Roundtable Q. 3, 2025-1055511C6 - Cash Pooling | Income Tax Act - Section 15 - Subsection 15(2.11) | PLOI election available re cross-border cash-pooling arrangement/ simplified PLOI election will be announced |
| Income Tax Act - Section 15 - Subsection 15(2.6) | frequent anticipated payments and repayments occurring in a cross-border physical or notional cash-pooling arrangement likely would be a s. 15(2.6) series | |
| Income Tax Act - Section 15 - Subsection 15(2.17) | illustration of ordering rule for determining whether s. 15(2.17) applies to a cross-border notional cash pooling arrangement | |
| 28 May 2025 IFA Roundtable Q. 4, 2025-1052581C6 - Requests for documents under section 231.1 | Income Tax Act - Section 231.2 - Subsection 231.2(1) | s. 231.1 is CRA's primary information-request power, and it uses s. 231.2 only in special situations, e.g., information about unnamed persons |
| Income Tax Act - Section 231.1 - Subsection 231.1(1) | CRA is now using s. 231.1 as its primary demand power, and is relegating s. 231.2 to special situations | |
| 28 May 2025 IFA Roundtable Q. 5, 2025-1063771C6 - Computation of FAT | Income Tax Act - Section 95 - Subsection 95(1) - Foreign Accrual Tax | formula for prorating foreign tax between a FAPI and non-FAPI business for FAT purposes |
| 28 May 2025 IFA Roundtable Q. 6, 2025-1052631C6 - Earnings of a disregarded US LLC | Income Tax Regulations - Regulation 5907 - Subsection 5907(2.03) | the opening UCC for used depreciable property of an acquired LLC for the first year of computing its (a)(iii) earnings was the lesser of UCC and FMV |