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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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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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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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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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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Principal Issues: Does clause (c)(ii)(A) of the definition of "total charitable gifts" in subsection 118.1(1) apply to a graduated rate estate...

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Position: See document

Reasons: See document

October 2016 APFF Roundtable

QUESTION 5

5A ELECTRIC VEHICLES AND ELECTRICITY COST DEDUCTION

Principal Issues: Whether the exception in paragraph (k) of the definition of salary deferral arrangement would be applicable in the situation...

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Principal Issues: 1- What is the tax treatment of an amount received by a vendor following cancellation of promise to purchase his/her personal...

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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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