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(a) In the first situation, since the down payment was fully paid by A, A will be considered to have made a gift of $50,000 to B at the time of purchase (50% × $100,000). ... Instead, could the ACB of each be allocated as follows: A: $250,000 ($100,000 + (50 % × $300,000)) B: $150,000 (50 % × $300,000) b) In the second situation, in CRA's opinion, pursuant to Art. 1015 C.C.Q. of the Civil Code, will each be required to report the following proceeds of disposition and ACB in 2021 A (50 %): $350,000- $200,000 B (50 %): $350,000- $200,000 Is it then reasonable to conclude that the $100,000 priority payment to A actually includes the repayment by B of a loan made to B by A at the time of purchase, being 50% of the $100,000 down payment, or $50,000? ... The CRA is of the view that the word "consideration" in the phrase "fair market value of any consideration … received by the donee for the disposition … of the security" in paragraph 118.1(13)(c) must be given the broad meaning generally accepted in the jurisprudence. ...

Element C in the s. 6(2) formula appears to contemplate that the cost of the automobile to a person (Holdco) related to the employer is to be taken into account – but 2014-0529991E5 appears to indicate that the leasing cost to Opco should instead be used. ... The formula in subsection 6(2) is worded as follows: A/B × [2% × (C × D) + 2/3 × (E – F)] Element C of this formula represents the cost of the automobile to the employer or to a person related to the employer if either of them owns the vehicle at any time in the year. ... Official response 6 October 2017 APFF Roundtable Q. 14, 2017-0720321C6 F- GAAR & 21-year rule planning Q.15 Step-up of goodwill on loss restriction event The sole asset of a corporation sold to a 3 rd party is goodwill with a fair market value of $200,000. ...

Prud'homme: We basically see two types of files concerning regular dividends – either there is safe income or there is not. ... In this scenario – where Canada maintains full ability to tax – are the businesses, undertakings and activities of B Co carried on in Canada? ... ATI is determined by the formula A + B – C, and A is determined by the formula D – E. ...

Can “actively engaged on a regular basis” in s. 120.4(1) – split income – (c)(ii)(D) be interpreted in the same way as "actively engaged on a regular and continuous basis" as defined in IT-349R3 and IT-268R4 (but with necessary adaptations to reflect the farming business context of the latter)? ... Official Response 9 October 2015 APFF Roundtable Q. 20, 2015-0595681C6 F- Avantages imposables / dépenses d’entreprise. ... Under the definition of “aggregate investment income” in s. 129(1), the corporation would have investment income of $34,000, comprised of a taxable capital gain of $18,000 and property income of $40,000 (i.e., $14,000 + $12,000 + $24,000-$10,000) minus the dividend deduction from taxable income of $24,000. ...

The Queen,[FN13: 2009 TCC 394 (" Richer ").] the Tax Court of Canada held that a debt is settled or extinguished when the creditor and debtor agree to fix or modify their existing rights and obligations, which occurs in January 2023. ... (" Leblond ").] the Court ordered the Deputy Minister of Revenue of Quebec to split an assessment, i.e., that the tax liability for the pre-proposal period of the arrangement was to be included in the provable claims for the proposal. ... In determining whether income is derived from property that is used or held principally for the purpose of gaining or producing income from an active business, the comments in paragraph 6 of IT-73R6 may be helpful: “6. […] It is a question of fact whether a property is used principally in an active business. ...

This is claimed by filing form T3A — Request for Loss Carryback by a Trust. ... Official Response 26 November 2020 STEP Roundtable Q. 13, 2020-0847201C6- GRE & section 216 election Q.14 Adjusted Aggregate Investment Income Subsection 125(5.2) is an anti-avoidance rule which may apply if a particular corporation transfers “property” at any time, either directly or indirectly to another corporation which is related to but not associated with the particular corporation, in circumstances where one of the reasons the loan or transfer was made was to reduce the “adjusted aggregate investment income” (“AAII”) of the particular corporation. ... Because of these strict requirements, practitioners have for years been concerned — and experienced the results of such concerns — that many estates may not be eligible for such planning because of the tight timelines and requirements for an actual disposition. ...

Is it just the taxpayer – is the taxpayer the unit of risk, so that taxpayers are either risky or not risky? ... Canadian law gives the Minister broad power to compel the production of information – the word “any” is there in the Act – but of course judges have imposed a reasonableness test. ... We are working around in the T1 space – letting taxpayers “load in” their T4. ...

Codifying those principles can be tricky – I understand why the drafters went with “appropriate in the circumstances.” ... The Communiqué puts some conditions around it – reasonableness and restraint. ... Not every file will be resolved this way – one of our criteria is that the adjustment in question must be at least $100 million. ...

Brault: The CRA is currently part of three ICAP 2.0 risk assessments – one is complete and two are still in progress. ... Brault: The document is in final stages of approval – it should hopefully be ready in weeks rather than months. ... There is quite a number of applications – over 2 million if you look period-by-period – so that 100% coverage is infeasible. ...

At the 2015 STEP – CRA Roundtable, CRA stated that an individual can only have one estate. ... Anyone wanting to access that Q & A, can go to the CRA website and use the search tool to enter in “graduated rate estate”- and the Q & A will be the first hit for the search. ... Further, the settlor / grantor can exercise his / her power to revoke the trust at any time. ...