7 October 2016 APFF Roundtable Q. 2, 2016-0652841C6 F - Changement partiel d’usage - immeuble locatif et résidentiel -- translation

Principal Issues:

Through an example, the CRA essentially was asked:

1-What is the CRA’s interpretation when a taxpayer sells a building where a...

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7 October 2016 APFF Roundtable Q. 1C, 2016-0652771C6 F - T106 and multiple year ends -- translation

Principal Issues: 1. If a corporation has two short tax years due to an acquisition of control, will the CRA accept that only one form T106 needs...

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7 October 2016 APFF Roundtable Q. 1B, 2016-0652761C6 F - T4A filing -- translation

Principal Issues: 1. What is the status of the CRA's administrative position with respect to the filing of T4A slips for professional services...

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7 October 2016 APFF Roundtable Q. 1A, 2016-0652951C6 F - Penalty late filed election-subsection 85(8) -- translation

7 October 2016 APFF Roundtable Q. 1A, 2016-0652951C6 F - Penalty late filed election-subsection 85(8)

Principal Issues: Whether the penalty for...

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9 October 2015 APFF Roundtable Q. 7, 2015-0595561C6 F - Computation of adjusted cost base and section 84.1 -- translation

Principal Issues: In a given scenario, whether subparagraph 84.1(2)(a.1)(ii) applies to reduce the adjusted cost base of shares for the purpose of...

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9 October 2015 APFF Roundtable Q. 6, 2015-0595551C6 F - Capital Dividend Account -- translation

Principal Issues: Impact of an amalgamation of corporations or the winding-up of a corporation on the calculation of the CDA.

Position: See...

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9 October 2015 APFF Roundtable Q. 5, 2015-0595651C6 F - Frais de garde subventionnés -- translation

Principal Issues: 1) Can the CRA confirm that the Additional Subsidized Childcare Contribution in Quebec is deductible in computing an...

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9 October 2015 APFF Roundtable Q. 3, 2015-0595761C6 F - Application of ss. 18(3.1) -- translation

Principal Issues: When applying ss. 18(3.1), will the CRA follow the reasoning adopted in the Janota case?

Position: General comments. It is...

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9 October 2015 APFF Roundtable Q. 2, 2015-0595521C6 F - Meaning of "actively engaged" -- translation

Principal Issues: (1) Whether CRA’s comments on the meaning of "actively engaged on a regular and continuous basis" expressed in the context of...

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9 October 2015 APFF Roundtable Q. 1, 2015-0595751C6 F - Deductibility of financing fees and 20(1)(e)(v) -- translation

Principal Issues: Can the remaining balance of financing fees be written off in a taxation year where the borrowing to which they relate is...

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