2013 CTF Round Table

The questions posed to CRA at the Round Table held yesterday at the annual CTF conference, together with brief notes of the responses, are now available for your viewing.  Some highlights:

• Q1.  CRA has published its new practices on pre-ruling consultations.
• Q2(b).  Where there is a mismatch in the loans amounts comprising a back-to-back loan to which s. 90(7) applies, the pay-down in the larger loan amount is treated as not going first to reduce the notional upstream loan.
• Q3.  CRA will not follow the purported expansion in CAE of when the change-in-use rules apply, and will stick with IT-102R2 and IT-218R.
• Q4(c).  Repetitive reporting on T1134s of tiered structures is no longer required.
• Q6.  CRA accepts Daishowa.
• Q8.  S. 214(7) deemed interest on a "regular" convertible debenture is not participating interest.
• Q11.  CRA's policy of allowing 3-party agreements to get around s. 55(3.2)(h) in cross-border butterflies is now well-established.
• Q15.  CRA did not accept using stock dividends to accomplish the approximate equivalent of a s. 85.1(3) drop-down.
• Q16(a).  Will CRA incentivize its auditors by paying 25% of all reassessments?

Neal Armstrong and K.A. Siobhan Monaghan.  2013 CTF Round Table.