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The length of time would have to be appropriate, so there is no set period of time – it depends on the circumstances as to which period should be considered to make the determination. ... There is a common theme with the two prior responses – crypto is subject to the same obligations of keeping proper supporting documentation, in respect of crypto asset transactions. ... The discretionary relief has to be requested in prescribed form – RC4288. ...

C’s income pursuant to s.104(13) would be considered to be US-source income – and we assume this throughout the rest of the answer. ... In many cases, however, the terms of the trust that is affected by subsection 75(2) will not have any amounts paid or payable to the contributor / settlor and ultimately the taxation of the applicable amounts in the contributor / settlor’s hands is only because of subsection 75(2) and not subsection 104(6). Accordingly, when preparing the accounting records for the trust, the subsection 75(2) attributed amounts are not recorded as being paid or payable to the contributor / settlor since the facts of the particular case will often not require the actual payment of such amounts to the contributor / settlor. ...

Although s. 107(2) is not applicable to this situation, consideration could be given to whether s. 248(1) – “disposition” – (f) or s. 107.4(3) could apply to allow the property to be transferred on a tax-deferred basis. ... In other words, whether or not a s. 256(9) election is made, the "?" ... Alternatively, if you do elect out, you will not get a roll-in on the transfer in – it will be at fair market value, and the trust will not have a deemed disposition or year-end on the death of the settlor. ...

To make a request to cancel penalties or interest, businesses or their authorized representatives should fill out Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties or Interest. ... Q.21- Court Cases / Objections Please provide an update on recent and current court cases and objections. ...

Meaning of "trust & loan corporation" CRA Comments Q.20. ... Meaning of "trust & loan corporation" Summary of Question A person whose principal activity is purchasing debt securities is a listed financial institution. ... QST administration by the Canada Revenue Agency: Quebec SLFI’S Summary of Question Pension entities with more than 90 % of their members in Quebec and less than 10% of their members in another province became Quebec SLFIs under the new Quebec Sales Tax ("QST") regime as of January 1st 2013. ...

See Taitz & Millar, ‘‘The GST and National Religious Organizations – Selected Issues”, GST & Commodity Tax (Carswell), Vol. ... The schedule to that Notice of Ways and Means Motion to Amend the Excise Tax Act contained the following text with respect to section 155: “ Section 155 — Non-Arm's Length Supplies by Public Sector Bodies: Section 155 provides an anti-avoidance rule that deems certain non-arm's length supplies made for less than fair market value to be made for fair market value. ... A determination of the LP’s primary purpose would generally reflect its main or fundamental purpose at the time it was established – and may be reassessed later on. ...

The CRA requires that form T2075 be filed twice – this is noted at the top of the form. ... A forgiven amount at any time is determined by the formula A – B, under that definition in s. 80(1). ... Official Response 15 June 2022 Roundtable, 2022-0924791C6- STEP 2022 – Q18- McNeeley et al v. ...

Potential abuse of integration principle However, the D & D Livestock case illustrates how s. 55(2) can be instrumental in not only preventing the duplication of taxes, but might also be instrumental in generating ACB that is unsupported by taxed corporate income. ... D & D Livestock addressed We will not go over the facts of D & D Livestock in detail. ... Some people have been wondering about the fact that in D & D, there was a sale that was contemplated and whether the changes to proposed s. 55(2) would be limited to circumstances where a potential buyer has been identified or where there is a potential sale as part of a series in the traditional sense or in the extended sense under s. 248(10). ...

S. 46(1) also does the same to proceeds of disposition – the greater of $1,000 or the amount otherwise determined. ... It is calculated first at the entity level – and nothing in this scenario would alter the nature of that calculation – and then the Canadian income inclusion under s. 91(1) is then determined on a share-by-share basis – again nothing in this scenario would alter the nature of that calculation. ... In the scenarios that are presented – either that the daughter disposes of the property within 24 months of her father’s death or she waits for more than 24 months – in both situations, because the farm has been owned continuously by Mr. ...

Preliminary response The conclusion in 2013-0509111E5 – that s. 94(2)(t) applied, but not in respect of the original transfer of shares by Corp X to Trust A – still stands. ... It serves to report information about the trust itself, but also information that affects the taxation of persons who happen to have some connection to the trust – beneficiaries, settlors, and contributors. ... This is not a new interpretation – it is consistent with 2000-0056385 F. ...