Search - "Contribution of Property" | Page 4

Our translations of CRA Interpretations go back over 11 years

Bundle Date Translated severed letter Summaries under Summary descriptor 2009-11-06 16 October 2009 Internal T.I. 2009-0337721I7 F- Perte lors de fusion étrangère Income Tax Act- Section 87- Subsection 87(8) claiming of capital loss in promptly-filed amended return would be accepted as an election Income Tax Act- Section 40- Subsection 40(3.5)- Paragraph 40(3.5)(b) s. 40(3.4) not applicable to foreign triangular merger to which s. 87(8) was elected not to apply 2009-10-30 20 October 2009 External T.I. 2009-0328441E5 F- Fiducie testamentaire Income Tax Act- Section 248- Subsection 248(8)- Paragraph 248(8)(a) unlikely to have been a distribution as a consequence of death where mooted testamentary trust formed by beneficiaries by their own agreement Income Tax Act- Section 75- Subsection 75(2) s. 75(2) would apply if heirs form a trust to provide for their sister out of the residue, with the remainder to them on her death 23 October 2009 External T.I. 2009-0309861E5 F- Tax-free Savings Accounts Income Tax Act- Section 143.2- Subsection 143.2(2)- Paragraph 146.2(2)(c) contribution by spouse causes cessation as TFSA Income Tax Act- Section 74.5- Subsection 74.5(12)- Paragraph 74.5(12)(c) s. 74.5(12)(c) inapplicable to contribution of property to TFSA of contributor’s spouse followed by spouse’s withdrawal of property and investment of proceeds 20 October 2009 External T.I. 2009-0327911E5 F- Fiducie non-résidente Contribuant résidant Income Tax Act- Section 94- Subsection 94(1)- Resident Contributor any period of residence in Canada even if prior to a period when the person was non-resident in Canada is included in computing the 60-month period 2009-10-23 13 October 2009 External T.I. 2009-0342091E5 F- Revenu d'emploi exonéré par Conv.- frais de garde Treaties- Income Tax Conventions- Article 19 employment income that was Treaty-exempt was to be reported (on a separate line), with the s. 110(1)(f)(i) deduction then claimed Income Tax Act- Section 63- Subsection 63(2) child care expenses could only be claimed by the spouse with the lower net income, notwithstanding that her income was Treaty-exempt ...

10 October 2024 APFF Roundtable

Whether the payment of professional fees by a trustee, beneficiary, or other person is considered to be a contribution of property indirectly made by that person to the trust for the purposes of subsection 75(2) is a question of fact requiring an analysis of all the facts and circumstances relating to a particular situation. ...

18 June 2015 STEP Roundtable Q. 13, 2015-0581941C6 - 2015 STEP - Q 13- T3 return Q 10

Q 10 on the T3 Return asks: "Did the trust receive any additional property by way of a contribution of property (as defined in the "Definitions" of the guide) since June 22, 2000? ... " The definition "contribution of property" in the Guide reads as follows: Contribution of property generally refers to a transfer or loan of property, other than an arm's length transfer, to a non-resident trust including: a series of transfers or loans that results in a transfer or loan to the non-resident trust; and a transfer or loan made as a result of a transfer or loan involving the non-resident trust. ... It now states as follows: "Contribution of property  generally refers to a transfer or loan of property, other than an "arm's length transfer" (as defined in subsection 94(1)) to a non-resident trust by a person or partnership. ...

8 March 2018 CBA Commodity Taxes Roundtable, Q.2 -- summary under Section 268

8 March 2018 CBA Commodity Taxes Roundtable, Q.2-- summary under Section 268 Summary Under Tax Topics- Excise Tax Act- Section 268 quaere whether a contribution on property by someone other than the settlor is a settlement of property If X settles a trust in 2013 with property and then in 2017 X, and Y, contributes more property to the trust. ...

15 June 2021 STEP Roundtable Q. 12, 2021-0885671C6 - Property owned jointly

15 June 2021 STEP Roundtable Q. 12, 2021-0885671C6- Property owned jointly Unedited CRA Tags 73(1), 73(1.01), 73(1.02), 104(4) Principal Issues: Is it possible for spouses to jointly create a trust which meets the conditions set out in subparagraph 73(1.01)(c)(iii) of the Act with a contribution of property jointly-owned by the spouses? ... Joint Spousal or Common-Law Partner Trust – Contribution of Jointly-Held Property Is it possible for spouses or common-law partners to jointly create a trust which meets the conditions set out in subparagraph 73(1.01)(c)(iii) of the Act with a contribution of property jointly-owned by the spouses or common-law partners? ...

4 April 1990 Internal T.I. 59857 F - Trust Designations in respect of Beneficiary

We have concluded from our review that where the income beneficiary of a trust has agreed to bear the burden with respect to the trust's taxes arising from a subsection 104(13.1) designation, the withholding of such taxes from the payment made to the beneficiary will not, in and by itself, result in a contribution of property to the trust for the purposes of subparagraph 108(1)(i)(ii) of the Act provided that the withheld amount relates to the income paid or payable to the beneficiary. ...

4 April 1990 Income Tax Severed Letter 5-9857 - Designation under subsection 104(13.1) related to a trust

We have concluded from our review that where the income beneficiary of a trust has agreed to bear the burden with respect to the trust's taxes arising from a subsection 104(13.1) designation, the withholding of such taxes from the payment made to the beneficiary will not, in and by itself, result in a contribution of property to the trust for the purposes of subparagraph 108(1)(i)(ii) of the Act provided that the withheld amount relates to the income paid or payable to the beneficiary. ...

4 April 1990 Income Tax Severed Letter AC59857 - Trust Designations in respect of Beneficiary

We have concluded from our review that where the income beneficiary of a trust has agreed to bear the burden with respect to the trust's taxes arising from a subsection 104(13.1) designation, the withholding of such taxes from the payment made to the beneficiary will not, in and by itself, result in a contribution of property to the trust for the purposes of subparagraph 108(1)(i)(ii) of the Act provided that the withheld amount relates to the income paid or payable to the beneficiary. ...

21 October 1993 External T.I. 9329015 F - RRSP Advantages

If the advantage remains in the RRSP, such as the earning of bonus interest in the plan or a contribution of property into the RRSP, this would not contravene the aforementioned provision. ...

7 March 1991 Income Tax Severed Letter - Tax implications of a payment of cash to the estate to enable it to pay the liabilities

A payment of cash to the estate to enable it to pay the liabilities will result in a contribution of property to the trust for the purpose of subparagraph 108(1)(ii) of the Act. ...

You are here

Search - "Contribution of Property"

Filter by Type: