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Email this Content 25 September 2017 CTF Finance Roundtable on 18 July 2017 Proposals Passive Income Q.1 – Effect on lower-bracket taxpayers Oral Response Q.2 – Calculating deferral on investment income Oral Response Q.3 – Principles affecting the proposals Oral Response Q.4- Grandfathering Oral Response Income-Sprinkling Q.5 – Complexity of TOSI Oral Response Q.6 – Difference in treatment of family transactions Oral Response Q.7 – Comparison of friends in business vs. family members Oral Response Surplus-Stripping Q.8 – Pipeline transactions Oral Response Q.9 – Effects on intergenerational transfers of family businesses Oral Response Q.10 – Scope of s. 246.1 Oral Response Q.11 – Non-ancillary s. 246.1 application to NAL transactions Oral Response General Q.12 – Implementation Oral Response Additional comment on tax advantage computation This summarizes the oral responses provided by two senior Finance officials at the Finance Roundtable held at the Infinity Convention Centre in Ottawa on 25 September 2017. ... I do not know precisely how the legislative proposals – I’ll focus on income sprinkling for the moment – will go forward – that is to say whether the next step is another draft, tabling, or something else. ... There is also the longer term – not years, but more than the next couple of weeks or months – where we need to consider whether to add exceptions or refinements to the rules. ...

Email this Content 27 October 2020 CTF Roundtable Q.1 – ACB increase in s. 55(3)(a)/88(1) reorg Preliminary Response Official Response Q.2 – Consolidation of safe income in a corporate group Preliminary Response Official Response Q.3 – Safe Income on Reorganization Preliminary Response Official Response Q.4 – Sale of taxable Canadian property by a partnership Preliminary Response Official Response Q.5 – Art. ... Treaty where further French layer Preliminary Response Official Response Q.6 – MLI and PPT Preliminary Response Official Response Q.7 – Use of cottage by children of settlor of AET/JST/CLPT Preliminary Response Official Response Q.8 – SDA rules and formula-based appreciation plans Preliminary Response Official Response Q.9 – UK LLPs as corporations Preliminary Response Official Response Q.10- Refreezes and s. 74.4(2) attribution quantum Preliminary Response Official Response Q.11 – Refinancing prescribed rate loans and attribution Preliminary Response Official Response Q.12 – Impact of COVID-19 on Previous APAs/Current MAPs Preliminary Response Official Response Q.13 – Reimbursement of Equipment Preliminary Response Official Response Q.14 – Section 86 Reorganization of Capital Preliminary Response Official Response This provides the text of the written questions that were posed, and summaries of the CRA oral responses, at the CRA Roundtable webinar hosted on 27 October 2020 by the Canada Tax Foundation. ... Official Response 27 October 2020 CTF Roundtable Q. 4, 2020-0862451C6- Sale of TCP by a partnership Q.5 – Art. ...

ETA 280.1: • Failure to file penalty applies (1% x $10,000) + (1% x $10,000 x ¼ x 5 months) Note: Although the return was due on Feb 28, 2007, the Budget Implementation Act provides that for purposes of section 280.1, returns due and outstanding prior to March 31, 2007, are deemed to be required to be filed on March 31, 2007. ... GEN – TCC: On December 23, 2004, the CMPA filed an appeal before the TCC. ... Q.43- Excise Taxes – End-User Refunds Please comment on the status of this review. ...

Email this Content 3 December 2019 CTF Roundtable Q.1 – Application of Multilateral Instrument (MLI) PPT Preliminary Response Official Response Q.2 – Translation under s. 126 of foreign taxes paid Preliminary Response- Q.2(a) Preliminary Response- Q.2(b) Official Response Q.3 – Translation of s. s. 55(5)(d)(i) TFSB at SIDT Preliminary Response Official Response Q.4- Ss. 84.1(1)(b) and 129(1)(a) Preliminary Response Official Response Q.5- S. 212.1(6) and post-mortem pipelines Preliminary Response Official Response Q.6- Distribution of TCP by resident trust to NR-owned corporate beneficiary Preliminary Response Official Response Q.7 – S. 120.4(1.1)(b)(ii) where share distribution by inter vivos trust on death Background – before Mr. ... In Scenario 1, the exchange rate of the US dollar is US $1 = CDN $1 at Time 1 and US $1 = CDN $1.2 at Time 2 At Time 2 Can Opco pays a dividend of $120 to Can Holdco In Scenario 2, the exchange rate of the US dollar is US $1 = CDN $1.2 at Time 1 and US $1 = CDN $1 at Time 2 At Time 2 Can Opco pays a dividend of $100 to Can Holdco. ... This implies a degree of correlation or direct substitution – one might say a “causal relationship” – between the disposition of the former property and the acquisition of the new one. ...

COPYRIGHT is reserved jointly to the CRA and the CBA Commodity Tax, Customs & Trade Section. ... CRA Response For the fiscal year 2008 – 2009 the following are the summary results: Summary of the 2008- 2009 fiscal year Total Income Tax Disclosures = 9,907 Total GST/HST Disclosures = 1,486 Total All = 11,393 Federal Tax = $392,384,192 Tax = $182,438,898 Total Tax = $574,823,090 There has been a small decline in GST/HST disclosures from previous years. For the fiscal year 2009 – 2010 to date the following are the summary results: Total Income tax and GST/HST disclosures = 10,000 Income change = $1.7Billion As an Agency we have reviewed the GST/HST WASH transactions policy. ...

The answer to questions # 1 and #2 would generally be the same for purposes of Division II, III or IV tax. ... Q.28- Zero-Rated Exports – Services (i) An estates lawyer prepares a will for a non-resident individual. ... Assume in this case that the Canadian does qualify under subsection 185(1) – i.e. the financing transaction relates to its commercial activities within CCRA’s policy guidelines – notably P-094 and P-108). ...

Email this Content 28 May 2015 IFA Roundtable Question 1 – George Weston: hedging impact Notes From Presentation Official Response Question 2- GAAR and treaty shopping Notes From Presentation Official Response Question 3 – Entity classification/LLLPs Notes From Presentation Official Response Question 4 – Upstream loans: s. 90(9) deduction Part A Part B Part C Notes From Presentation Official Response Question 5 – Back-to-back loans: “because” test Notes From Presentation Official Response Question 6 – s. 95(2)(a)(ii)(D) and contribution of capital Notes From Presentation Official Response Question 7 – FA mergers and deficit double counting Notes From Presentation Official Response Question 8 – S. 39(2.1) and s. 261(10) inclusion Notes From Presentation Official Response Question 9 – s. 95(2)(i) re purchase note Notes From Presentation Official Response Question 10 – 111(4)(e) step-up and 212.3(2) Notes From Presentation Official Response Question 11 – FA borrows to pay dividend Notes From Presentation Official Response Question 12 – Conflicting versions of Swiss Treaty Notes From Presentation Official Response Presentation by Phil Halvorson (of Finance until 1 May 2015, but in a non-representative capacity) on BEPS Question 1 – George Weston: hedging impact The Tax Court of Canada recently rendered its decision in the George Weston Ltd. ... Official Response 28 May 2015 IFA Roundtable, Q. 9, 2015-0581581C6 Question 10 – 111(4)(e) step-up and 212.3(2) Following an acquisition of control, paragraph 111(4)(e) permits a taxpayer to make a designation in respect of certain capital property in order to deem a disposition and reacquisition of that capital property. ... Official Response 28 May 2015 IFA Roundtable, Q. 10, 2015-0581641C6 Question 11 – FA borrows to pay dividend Paragraph 95(2)(a) of the Act re-characterizes, in various circumstances, amounts that would otherwise be income from property of a foreign affiliate as income from an active business. ...

Tax on Split Income – Excluded Shares CRA Response Q6. Tax on Split Income – Business Sale CRA Response Q7. ... Change in FMV – NRRPR CRA Response Q11. CRA My Business Account – View filed numbers CRA Response Q12. ... RC4188 – What you should know about audits, and IC98-1R7 – Tax Collections Policies. ...

The Queen Facts / Background Question CRA Comments Q.4- Real Proeprty Transactions: Liability To Remit Gst Facts / Background Analysis Question CRA Comments Q.5- Small Supplier Threshold: Multiple Owners of Bed & Breakfast Facts / Background Question CRA Comments Q.6- Nursing Homes Facts / Background Questions CRA Comments Q.7- 191(3) And Itcs Facts / Background Question CRA Comments B. ... The basic tax content was: (A- B) × C = ($7,000- 0) × the lesser of 1 and ($50,000/$100,000) = $3,500 In December 2003, the commercial use of the property decreased to 35%. ... Under ETA 200 (2), ABC was deemed to have collected GST equal to the basic tax content, which was: (A- B) × C = ($3,500- 0) × the lesser of 1 and ($50,000/?) ...

• NRCo owns Forco. Forco owns 100% of a Canadian operating subsidiary (CanOpco). ... " CRA also would need to consider the business activities of: · the CRIC; · all corporations resident in Canada with which the CRIC does not at the investment time, deal at arm's length; · the subject corporation; · all subject subsidiary corporations, as that term is described in s. 212.3(16)(a); and · all non-resident corporations with which the CRIC, at the investment time, does not deal at arm's length, other than any corporation that is, immediately before the investment time, a controlled foreign affiliate of the CRIC for the purposes of s. 17. ... Official Response 23 May 2013 IFA Round Table, Q. 6h, 2013-0483751C6 Q. 7 – Thin capitalization • Assume that a Canadian subsidiary has two loans outstanding to specified non-residents: its US Parent and a UK related company. ...