| 29 November 2022 CTF Roundtable Q. 1, 2022-0949781C6 - Loans Made by Limited Partnerships to Limited Partners |
Income Tax Act - Section 40 - Subsection 40(3.1) |
purpose of policy re annual reversing loans by an LP to its limited partners is only to address timing mismatches |
| 29 November 2022 CTF Roundtable Q. 2, 2022-0950501C6 - Section 116 and Taxable Canadian Property |
Income Tax Act - Section 116 - Subsection 116(5) |
CRA generally will not provide advance guidance on TCP status |
| 29 November 2022 CTF Roundtable Q. 3, 2022-0949771C6 - Post-closing adjustments and the impact to escrow shares |
Income Tax Act - Section 84 - Subsection 84(3) |
cancellation of escrow shares triggered a deemed dividend |
| 29 November 2022 CTF Roundtable Q. 4, 2022-0950561C6 - Servers/Data Centres and Location of Services Rendered |
Treaties - Income Tax Conventions - Article 5 |
remote customer-support services from the US did not cause a Canadian services PE |
| Income Tax Regulations - Regulation 105 - Subsection 105(1) |
remote customer support services were accessory in nature and were not rendered in Canada |
| 29 November 2022 CTF Roundtable Q. 5, 2022-0949751C6 - The New Proposed Critical Mineral Exploration Tax Credit |
Income Tax Act - Section 127 - Subsection 127(9) - Flow-Through Critical Mineral Mining Expenditure |
the critical METC certification form will be provided shortly |
| 29 November 2022 CTF Roundtable Q. 6, 2022-0950671C6 - Guidance on Crypto-asset Taxation and Reporting |
Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(d) |
T1 and related forms to be modified for 2022 to provide further guidance re crypto asset dispositions |
| 29 November 2022 CTF Roundtable Q. 7, 2022-0951051C6 - Permanent Establishment and Mining Activities |
Treaties - Income Tax Conventions - Article 5 |
where a UK company remotely operated crypto-mining equipment located on a Canadian host company’s premises, the equipment constituted a Canadian PE |
| 29 November 2022 CTF Roundtable Q. 8, 2022-0951041C6 - CCA class of Crypto-Asset Mining Hardware |
Income Tax Regulations - Schedules - Schedule II - Class 50 |
crypto-mining GPUs and ASICS could qualify as Class 50 assets |
| 29 November 2022 CTF Roundtable Q. 9, 2022-0950531C6 - Multiple Wills and T3 Reporting |
Income Tax Act - 101-110 - Section 104 - Subsection 104(1) |
there is only one estate (and one T3 return) for a deceased, even if there are multiple wills |
| Income Tax Act - 101-110 - Section 104 - Subsection 104(2) |
s. 104(2) cannot apply where there are multiple wills since there is only one trust |
| 29 November 2022 CTF Roundtable Q. 10, 2022-0950581C6 - Common Reporting Standard |
Income Tax Act - Section 270 - Subsection 270(1) - Controlling Persons |
indirect distributions include receiving favourable loan terms/ settlor includes a substantive contributor |
| 29 November 2022 CTF Roundtable Q. 11, 2022-0949761C6 - Earnout Agreement |
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) |
earnout based on subsidiary goodwill/ counting of the 5-year limitation/ when amount becomes payable |
| 29 November 2022 CTF Roundtable Q. 12, 2022-0950591C6 - T1134 |
Income Tax Act - Section 233.4 - Subsection 233.4(4) |
questions on T1134 completion, and link to Q&A page |
| 29 November 2022 CTF Roundtable Q. 13, 2022-0950641C6 - Part XIII Tax on Royalties Paid on Broadcasting |
Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(vi) |
longstanding according of the copyright exemption to broadcasting (and perhaps other performance) royalties is reversed |
| 29 November 2022 CTF Roundtable Q. 14, 2022-0950551C6 - Charity's gift to grantee org |
Income Tax Act - Section 168 - Subsection 168(1) - Paragraph 168(1)(f) |
Guidelines on directed donations |
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