7 October 2016 APFF Roundtable Q. 19, 2016-0655841C6 F - Reimbursement of attributed income -- translation

Principal Issues: Does income that is attributed or allocated to another taxpayer, under certain specified provisions of the Act, need to be...

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7 October 2016 APFF Roundtable Q. 18, 2016-0652791C6 F - Taxable Canadian property and Part XIII tax -- translation

Principal Issues: Can a non-resident individual holding shares of a Canadian corporation that have been deemed to be disposed of upon the...

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7 October 2016 APFF Roundtable Q. 17, 2016-0652781C6 F - Functional currency and acquisition of control -- translation

Principal Issues: 1. Does the CRA consider that a deferred gain resulting from the application of subsection 261(10) can be realized in the year...

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7 October 2016 APFF Roundtable Q. 14, 2016-0655921C6 F - Safe income on hand - Preferred shares -- translation

PRINCIPAL ISSUES: In a particular situation, there is a class of preferred shares that are non-voting, non-participating, with a redemption value...

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18 October 2016 External T.I. 2015-0608051E5 F - Emigration of a trust -- translation

Principal Issues: 1.Whether a trust that ceases to be resident in Canada can make an election under subsection 220(4.5)? 2. Whether the Minister...

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7 October 2016 APFF Roundtable Q. 12, 2016-0655911C6 F - Partial Leveraged Buy-Out and Monetization of ACB -- translation

Principal Issues: Whether subsection 84(2) and/or 245(2) would apply in a situation involving a partial leveraged Buy-out.

Position: General...

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7 October 2016 APFF Roundtable Q. 11, 2016-0652941C6 F - Contrat de location / Capital lease -- translation

Principal Issues: Is the asset recorded as a capital property as a result of a lease of an asset considered used principally in an active business...

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7 October 2016 APFF Roundtable Q. 10, 2016-0652931C6 F - Bien agricole admissible-saisine par succession -- translation

Principal Issues: Whether the condition under subparagraph 110.6(1.3)(a)(i) is met when a child acquires a land from his estate’s father during...

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7 October 2016 APFF Roundtable Q. 9, 2016-0652921C6 F - Résidence - actif utilisé / Residence - asset used -- translation

Principal Issues: Does the CRA position in paragraph 22 of Interpretation Bulletin IT-268R4 apply to a person who is a shareholder but not an...

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7 October 2016 APFF Roundtable Q. 7, 2016-0652971C6 F - Paragraph 251(5)(b) and subsection 256(1.4) -- translation

Principal Issues: (1) Whether a power of attorney to find a prospective buyer for the shares of the capital stock of a corporation held by a...

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