10 fully translated 2015 APFF Roundtable items are available

17 January 2017 - 11:59pm
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Full-text translations of the first 10 questions from the 2015 APFF Roundtable are now available and are listed and briefly described in the table below. Q.5 (respecting the timing of child care deductions) was not answered at the time, so that the table below instead references the answer which was released a few weeks later as a technical interpretation.

These (and the other translations covering the last 13 months of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2015-12-09 9 October 2015 APFF Roundtable Q. 1, 2015-0595751C6 F - Deductibility of financing fees and 20(1)(e)(v) Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) discharge of a debt through its assumption or cash proceeds from sub transferee denies a s. 20(1)(e)(v) deduction
9 October 2015 APFF Roundtable Q. 2, 2015-0595521C6 F - Meaning of "actively engaged" Income Tax Act - Section 120.4 - Subsection 120.4(1) - split income - (c) - (ii) - (D) IT-349R3 and IT-268R4 potentially relevant to meaing of "actively engaged on a regular basis"
9 October 2015 APFF Roundtable Q. 3, 2015-0595761C6 F - Application of ss. 18(3.1) Income Tax Act - Section 18 - Subsection 18(3.1) - Paragraph 18(3.1)(a) no capitalization of repair/maintenance expenses incurred during renovation etc.
9 October 2015 APFF Roundtable Q. 4, 2015-0595541C6 F - Computation of taxable benefit Income Tax Act - Section 15 - Subsection 15(1) determination of normal yield re shareholder-provided luxurious property
23 October 2015 External T.I. 2015-0614231E5 F - Frais de garde subventionnés Income Tax Act - Section 63 - Subsection 63(1) additional Quebec child care contribution is deductible in the care year rather than the subsequent return-filing year (assuming timely payment to ARQ)
9 October 2015 APFF Roundtable Q. 6, 2015-0595551C6 F - Capital Dividend Account Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(z.1) amalgamation can cause a combined positive CDA balance to be zeroed
Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account capital loss does not eliminate positive CDA contribution of capital dividend received
9 October 2015 APFF Roundtable Q. 7, 2015-0595561C6 F - Computation of adjusted cost base and section 84.1 Income Tax Act - Section 84.1 - Subsection 84.1(2) - Paragraph 84.1(2)(a.1) terminal-return capital gains exemption claimed on bequested shares grinds their ACB for s. 84.1 purposes to the family beneficiaries
9 October 2015 APFF Roundtable Q. 8, 2015-0595591C6 F - Dividend Refund and Part IV Tax Payable Income Tax Act - Section 129 - Subsection 129(1) unclaimed divided refunds do not generate s. 186(1)(b) tax to the dividend recipient
9 October 2015 APFF Roundtable Q. 9, 2015-0595661C6 F - Question 9 - Table Ronde APFF 2015 Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) s. 20(1)(m) reserve may be claimable for an amount included under s. 9 rather than 12(1)(a)
Income Tax Act - Section 9 - Timing damages clause might represent a condition permitting deferral of income recognition
23 October 2015 External T.I. 2015-0614231E5 F - Frais de garde subventionnés Income Tax Act - Section 63 - Subsection 63(1) additional Quebec child care contribution is deductible in the care year rather than the subsequent return-filing year (assuming timely payment to ARQ)
9 October 2015 APFF Roundtable Q. 10, 2015-0595671C6 F - Question 10 - Table Ronde APFF 2015 Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose generally whould be reimbursement for expenses incujrred for affiliate
General Concepts - Effective Date price adjustment clause not required to reduce income for an excessive management fee