CRA releases 2020 IFA Roundtable items

11 November 2021 - 11:07pm
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CRA has published under its severed letter program the official versions of the first five questions and answers at the 2020 IFA Roundtable. We discussed these items at the time, but for convenience of reference are providing the table below with links to the items and our summaries of them. Questions 6 and 7 continue to be available on our Roundtables page.

Topic Descriptor
15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F - IFA 2020 Roundtable – T2057 & Functional Currency Income Tax Act - Section 261 - Subsection 261(5) - Paragraph 261(5)(a) different currency reporting of s. 85(1) rollover where one party has elected a funcitional currency
Income Tax Act - Section 85 - Subsection 85(1) dual-currency filing of s. 85 elections where the transferor and transferee have different tax reporting currencies
15 September 2020 IFA Roundtable Q. 2, 2020-0852741C6 - IFA 2020 - Q2 - WHT on mismatched swap payments Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) interest not imputed on mismatched cross-border swap payments
15 September 2020 IFA Roundtable Q. 3, 2020-0853371C6 - IFA 2020 Q3: Draft IC71-17R6, Paragraph 43 Treaties - Income Tax Conventions - Article 26 Canada does not negotiate away its application of domestic anti-avoidance rules
Income Tax Act - Section 247 - New - Subsection 247(2) - Paragraph 247(2)(b) ss. 247(2)(b) and 245(2) treated the same for MAP procedure purposes
15 September 2020 IFA Roundtable Q. 4, 2020-0853391C6 - IFA 2020 Q4: Impact Covid-19 on CRA procedures Income Tax Act - Section 152 - Subsection 152(4) no extension under Bill-20 (re COVID) beyond December 31, 2020
Treaties - Income Tax Conventions - Article 26 COVID-19 has not changed Treaty time limitations
15 September 2020 IFA Roundtable Q. 5, 2020-0853401C6 - IFA 2020 Q5: TPM-17 and COVID-19 Income Tax Act - Section 247 - New - Subsection 247(2) - Paragraph 247(2)(a) Canadian governmental COVID assistance likely will not reduce cost under cost-plus transfer-pricing methods
Treaties - Income Tax Conventions - Article 9 Cdn governmental COVID assistance generally does not reduce cost