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29 November 2016 CTF Roundtable Q. 1, 2016-0669301C6- GAAR & 21-year rule planning-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) avoidance of 21-year rule through 107(2) transfer to corporate beneficiary A discretionary resident trust that is approaching its 21st anniversary distributes property with an unrealized gain to a corporate beneficiary that is wholly owned by a newly-established discretionary trust. ...

29 April 2008 External T.I. 2006-0215891E5 F- Partnership Interest & Departure Tax-- summary under Subparagraph 220(4.5)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(4.5)- Paragraph 220(4.5)(a)- Subparagraph 220(4.5)(a)(i) s. 85(1) rollover of the property triggered the s. 220(4.5) deferred tax On his emigration from Canada, Mr. ...

29 April 2008 External T.I. 2006-0215891E5 F- Partnership Interest & Departure Tax-- summary under Paragraph 85(1.1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1)- Paragraph 85(1.1)(b) partnership interest is eligible property After emigrating from Canada, an individual transferred his interest in a real estate partnership on a s. 85(1) rollover basis to a corporation of which he was the sole shareholder. ...

21 September 2007 External T.I. 2007-0229191E5 F- Agent de voyages & impôt de la partie I.3-- summary under Subparagraph 181(3)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3)- Paragraph 181(3)(b)- Subparagraph 181(3)(b)(i) customer advances received by travel agents and reported as deferred revenue in their balance sheets were required to be included in taxable capital even though amounts held in trust Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them in a trust account, and also, in their year end balance sheets, reported the current balances in the trust accounts as assets and also as liabilities, labelled as "customer deposits and deferred revenue". ...

21 September 2007 External T.I. 2007-0229191E5 F- Agent de voyages & impôt de la partie I.3-- summary under Paragraph 181.2(3)(c) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(3)- Paragraph 181.2(3)(c) customer advances received by travel agents and reported as deferred revenue in their balance sheets were “advances” Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them in a trust account, and also, in their year end balance sheets, reported the current balances in the trust accounts as assets and also as deferred-revenue liabilities. ...

21 January 2008 External T.I. 2007-0227531E5 F- GRIP / GRIP Addition for 2006-- summary under Subsection 89(14) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(14) for 2006 only, CRA accepted designating a portion of a dividend as an eligible dividend Where, in 2006, Bco's GRIP is $1.3 M and, pursuant to s. 84(3), Bco is deemed to have paid a dividend of approximately $1M to Cco and Dco (approximately $500,000 each), can Bco designate a fraction of the deemed dividend representing Bco's safe income on hand attributable to the purchased shares (approximately $700,000) as an eligible dividend, pursuant to s. 89(14)? ...

2 May 2005 Internal T.I. 2005-0119971I7 F- CDA- Excessive Election & Late Filed Election-- summary under Subsection 184(3) Summary Under Tax Topics- Income Tax Act- Section 184- Subsection 184(3) where the corporation failed to file s. 83(2) election, CRA should assess Pt. ...

4 May 2005 External T.I. 2005-0120271E5 F- Change of Control- CDA & RDTOH-- summary under Clause 256(7)(a)(i)(A) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(7)- Paragraph 256(7)(a)- Subparagraph 256(7)(a)(i)- Clause 256(7)(a)(i)(A) s. 256(7)(a)(i)(A) applied where taxpayer acquired shares of CCPC from his sister Ms. ...

6 October 2017 APFF Roundtable Q. 1, 2017-0708971C6 F- Inactive Corporations & subs. 162(7) ITA-- summary under Paragraph 150(1)(a) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1)- Paragraph 150(1)(a) requirement for Canco to file nil T2 returns, but no penalty What was the CRA position on: (a) the obligation of an inactive Canadian corporation to file a T2 return for each of the years in which there is no business activity and, thus, no tax payable; and (b) the application of late-filing penalties? ...

6 July 2018 External T.I. 2018-0759521E5- Tax on split income & preferred beneficiary-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (c) income to preferred beneficiary is not split income A trust that is a limited partner of a partnership (“LP”) providing back office support to a general partnership of accounting professionals (“Partnership”) as its only source of income has a minor disabled beneficiary who qualifies as a “preferred beneficiary.” ...