| 2018-04-11 |
6 October 2017 APFF Roundtable Q. 1, 2017-0708971C6 F - Inactive Corporations & subs. 162(7) ITA |
Income Tax Act - Section 162 - Subsection 162(7) |
no penalty imposed where failure to file a nil T2 return |
| Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a) |
requirement for Canco to file nil T2 returns, but no penalty |
| 6 October 2017 APFF Roundtable Q. 2, 2017-0709001C6 F - T4A filing obligation |
Income Tax Regulations - Regulation 200 - Subsection 200(1) |
penalty applicable but not necessarily applied for failure to complete fee box |
| Income Tax Act - Section 162 - Subsection 162(7) |
"temporary" policy for not applying penalties for failure to issue T4As to independent contractors |
| 6 October 2017 APFF Roundtable Q. 3, 2017-0709011C6 F - Désignation d’un bien comme résidence principale |
Income Tax Act - Section 54 - Principal Residence - Paragraph (c) |
an individual accessing the “+1” rule on a principal residence disposition need not complete Form 2091 |
| Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) |
no loss of bonus year if standard designation |
| Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) |
no loss of bonus year if standard designation |
| 6 October 2017 APFF Roundtable Q. 4, 2017-0709021C6 F - CDA and Winding-up of a corporation |
Income Tax Act - Section 88 - Subsection 88(2) - Paragraph 88(2)(b) - Subparagraph 88(2)(b)(i) |
CRA will accommodate a s. 88(2)(b)(i) capital dividend election based on an estimated CDA balance |
| 6 October 2017 APFF Roundtable Q. 5, 2017-0709031C6 F - T2054 - Short Cut Method |
Income Tax Act - Section 184 - Subsection 184(3) |
the “short-cut method” for short-circuiting a Pt III assessment is “generally" available |
| 2013-10-23 |
25 September 2013 External T.I. 2013-0488571E5 F - Repayment of a dividend |
General Concepts - Effective Date |
taxpayer generally cannot change his legal position through a subsequent board or shareholder resolution |
| Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) |
dividend declared cannot be nullified by subsequent board or shareholder resolution |
| 2013-10-09 |
25 November 2012 Roundtable, 2013-0479401C6 F - Employés et Achat Ltée commentaires panel ARC |
Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) |
Buyco that is formed by employer to purchases departing employees’ shares is NAL |
| Income Tax Act - Section 84.1 - Subsection 84.1(1) - Paragraph 84.1(1)(b) |
generally a deemed dividend on repurchase of departing employees’ shares by employer-funded Buyco |
| 11 July 2013 External T.I. 2013-0490591E5 F - Montant pour une personne à charge |
Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) - Subparagraph 118(1)(b)(ii) |
conditions not satisfied where children did not live with non-supporting husband following separation |
| Income Tax Act - Section 248 - Subsection 248(1) - Common-Law Partner |
can be in a conjugal relationship even if live in the same home for only half of each year |
| Income Tax Act - Section 2 - Subsection 2(1) |
sole fact of a non-resident having a conjugal relationship with a Canadian resident does not render him a resident |
| 2013-10-02 |
18 September 2013 External T.I. 2012-0462061E5 F - Amount included in the income of the annuitant |
Income Tax Act - Section 146 - Subsection 146(8.3) |
no application of s. 148(8.3) where excluded withdrawal followed by contribution and withdrawal from own RRSP |
| 25 September 2013 External T.I. 2013-0477571E5 F - Partnership - fin. fees and mng fees |
Income Tax Regulations - Regulation 402 - Subsection 402(7) |
service performed by service to partnership must have been previously performed by a partnership employee and relate to a short-term task |
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