7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 2, 2016-0651711C6 F - RRIF, Transfer of designated benefit -- translation

Principal Issues: Does the designated benefit eligible to be transferred to the surviving spouse's RRIF or RRSP under paragraph 60(l) have to be...

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7 October 2016 APFF Financial Strategies and Instruments Roundtable Q. 1, 2016-0651771C6 F - Critical Illness Insurance -- translation

Principal Issues: Whether subsection 15(1) could apply to the transfer (without consideration) by a corporation of its critical illness insurance...

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7 October 2016 APFF Roundtable Q. 21, 2016-0655901C6 F - Section 7 and bonus paid in share -- translation

Principal Issues: 1) Will section 7 and subsection 7(1.1) apply to the issuance of shares when those shares are issued as a payment of a bonus...

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7 October 2016 APFF Roundtable Q. 20, 2016-0655831C6 F - Employee Buycos and the Poulin Case -- translation

Principal Issues: Whether our position with respect to Employee Buycos, as stated at the CRA Panel held at the 2012 CTF Annual Conference, has...

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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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