7 further translations of APFF Roundtable questions are available

31 December 2018 - 12:03am
Email this ContentEmail this Content

These days you just can’t get staff to work on Christmas. Nonetheless, we have released another 7 full-test translations of APFF Roundtable items. These consist of the final 5 items from the 2018 APFF Financial Strategies and Instruments Roundtable and 2 items from the 2012 APFF Roundtables.

These are additions to our set of 740 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 years of releases by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for January.

Bundle Date Translated severed letter Summaries under Summary descriptor
2018-12-12 5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 7, 2018-0761511C6 F - Rollover to spousal trust on death Income Tax Act - Section 70 - Subsection 70(6) - Paragraph 70(6)(b) - Subparagraph 70(6)(b)(ii) tainting effect of the payment by a spousal trust of premiums on its policy on the lives of the children
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 8, 2018-0761541C6 F - HBP withdrawals straddling two calendar years Income Tax Act - Section 146.01 - Subsection 146.01(2) - Paragraph 146.01(2)(d) factors considering in extending period for making backdated withdrawals
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F - Attribution rules and promissory note General Concepts - Payment & Receipt promissory note could not be issued as payment in context of income attribution rules
Income Tax Act - Section 74.5 - Subsection 74.5(2) - Paragraph 74.5(2)(b) accrued interest cannot be “paid” for s. 74.7 purposes by issuing a promissory note
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 11, 2018-0761571C6 F - Missing info on disposition of principal residence Income Tax Act - Section 54 - Principal Residence - Paragraph (c) CRA is only waiving penalties for late-filed principal residence dispositions for 2017 and 2016 returns
Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) description of filing requirements
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 12, 2018-0761581C6 F - Foreign Tax Credits related to mutual funds Income Tax Act - Section 126 - Subsection 126(1) CRA is no longer requesting country-by-country breakdowns of income derived from mutual funds in its FTC audits
2012-12-24 5 October 2012 Roundtable, 2012-0451291C6 F - Subsection 85(1) and UMIR Marketplace Rules Income Tax Act - Section 85 - Subsection 85(1) s. 85(1) no available where shares transferred to holding company through the exchange
5 October 2012 Roundtable, 2012-0453941C6 F - Principal residence owned by a trust-exemption Income Tax Act - Section 54 - Principal Residence - Paragraph (c.1) status based on s. 248(25) application and actual habitation
Income Tax Act - Section 54 - Principal Residence - Paragraph (f) renunciation by specified beneficiaries immediately before sale would not affect para. (f) exclusion