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

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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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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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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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Principal Issues: Is a taxpayer considered to be performing duties of a temporary nature for the purpose of subparagraph 6(6)(a)(i)?

Position: Yes...

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Principal Issues: 1. Does the payment qualify as a royalty prepayment ? 2. Should the payment be included into income as per paragraph 12(1)(a) or...

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Principal Issues: In a particular situation, Aco holds all of the issued and outstanding shares of the capital stock of Bco. Both corporations are...

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