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CRA is willing to take a policy-based approach to issues re the effect of s. 55(2) on ACB

Summaries of 27 November 2018 CTF Roundtable, Q.2 under s. 52(2), s. 52(3), s. 53(1)(b)(ii) and s. 89(1) – capital dividend account- (a)(i)(A). ...

Acquisition of Agellan REIT entails planning to realize accrued gain on cross-border USD loans

Summary of Agellan Commercial REIT Circular under Mergers & Acquisitions –REIT/Income Fund/ LP Acquisitions- LP Acquisitions of Trusts. ...

6 further translations of CRA interpretations are available

These are additions to our set of 759 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ¼ years of releases by the Directorate. ...

CRA confirms that it will not apply s. 112(3) to a dividend that has been subjected to s. 55(2) and discusses animating policy considerations

Summaries of 27 November 2018 CTF Roundtable Q. 2, 2018-0780071C6 under s. 112(3)(b)(i), s. 52(2), s. 52(3), s. 53(1)(b)(ii) and s. 89(1) – capital dividend account- (a)(i)(A). ...

Six further full-text translations of CRA interpretations are available

These are additions to our set of 777 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ½ years of releases by the Directorate. ...

CRA agreed to fictional transfer pricing adjustments and rules that they also did not affect the exempt surplus calculation (other than for the foreign taxes adjustment)

., its earnings as computed in accordance with the Country A income tax law – but that such adjustments were to be added to its earnings pursuant to Reg. 5907(2)(f), stating in its summary in the latter regard that: The money realized and retained by the foreign affiliate [i.e., Forco 1], but excluded from its income for foreign income tax purposes as a result of the corresponding adjustment by the foreign tax authority, would be "revenue, income, or profit" derived by the foreign affiliate for purposes of paragraph 5907(2)(f).... ...

CRA indicates that a health and welfare trust can administer a plan that is funded only with union or employee contributes where it also has employer-funded plans

., a group sickness or accident insurance plan (“GSAIP”), a private health services plan (“PHSP”), or a group term life insurance policy (“GTLIP”)) allows for the provision of benefit coverage to such individuals – although a GTLIP may only provide benefit coverage to current and former (including retired) employees. ...

CRA considers shares of Targetco now held 100% by Acquisitionco, and with a formal delisting imminent, to still be listed

Summary of 4 March 2019 Joint Committee Submission on Definition of “Public Corporation” under s. 89(1)- public corporation – para. ...

6 more translated CRA interpretations are available

These are additions to our set of 807 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ¾ years of releases by the Directorate. ...

CRA analyses the consequences of the recipient of trust distributions not in fact qualifying as a beneficiary

If Y and Z argued that s. 104(13) did not apply to them because no amount was payable to them in the year, CRA would apply s. 56(2) or (alternatively) s. 105(1) to include the dividend amounts in their income – but without any s. 104(6) deduction to the Trust. ...

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