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Chapter 19 - 8515 & 8516 – Special Rules for Designated Plans & Eligible Contributions

Chapter 19- 8515 & 8516 – Special Rules for Designated Plans & Eligible Contributions On this page... 19.1 8515(1) – Designated Plan 19.2 8515(2) – Designated Plan in Previous Year 19.3 8515(3) – Exceptions 19.4 8515(3.1) – Exceptions 19.5 8515(4) – Specified Individual 19.6 8515(5) – Eligible Contributions 19.7 8515(6) – Funding Restriction 19.8 8515(7) – Maximum Funding Valuation 19.9 8515(8) – Restricted-Funding Members 19.10 8515(9) – Member Contributions 19.11 8516(1) – Prescribed Contribution 19.12 8516(2) – Funding on Termination Basis 19.13 8516(3) – Contributions Required by Pension Benefits Legislation 19.1 8515(1) – Designated Plan An RPP with a DB provision is a designated plan throughout a year if the pension credits of specified individuals (defined in subsection 8515(4) of the Regulations) exceed 50% of all pension credits for the year under the provision. ... Cross references: Specified Individual – 8515(4) Eligible Contributions – 8515(5) Restricted-Funding Members – 8515(8) Member Contributions – 8515(9) FAQ No. 25 – Ministerial Waivers Under 8515(2) 19.3 8515(3) – Exceptions A plan will not become a designated plan if the following conditions are met: The plan would not be a designated plan in the year if the reference in paragraph 8515(1)(b) of the Regulations to “50%” were read as “60%”; The plan was established before the year; and The plan did not meet the condition under subsection 8515(1) of the Regulations to be a designated plan in the immediately preceding year. ... Cross references: Definition of Designated Plan – 8500(1) Designated Plan in a Previous Year – 8515(2) 19.5 8515(4) – Specified Individual An individual is a specified individual in a calendar year if the individual is connected at any time with a participating employer under the plan or the individual’s total remuneration for the year exceeds 2½ times the YMPE for the year. ...

Loupy’s – Tax Court of Canada confirms that a backdated GST registration has retroactive effect – and that winding-down operations qualified a de-registrant as a “registrant”

12 December 2016- 11:39pm Loupy’s – Tax Court of Canada confirms that a backdated GST registration has retroactive effect – and that winding-down operations qualified a de-registrant as a “registrant” Email this Content When the operator of a restaurant ceased operations due to a termination of its lease, it applied for and was granted a revocation of its GST and QST registrations. ... Favreau J found that, notwithstanding the revocation of its revocation, the taxpayer was still a “registrant” – whose definition includes a “person who is required to be registered”- given that it still held equipment which it was seeking to sell (some of which it sold eight months’ later). ...

Rio Tinto Alcan – Tax Court of Canada finds that investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 and 20(1)(bb) – and $17M in legal fees were deductible under s. 20(1)(cc)

18 July 2016- 11:31pm Rio Tinto Alcan – Tax Court of Canada finds that investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 and 20(1)(bb) – and $17M in legal fees were deductible under s. 20(1)(cc) Email this Content Hogan J articulated a distinction between (currently deductible) “expenses linked to [board] oversight [,which] are current expenses since they relate to the management of the process of producing income of the corporation,” and (capital-account) “expenses incurred in the course of implementing a transaction leading to the acquisition of capital property.” ... The alternative deductibility of these same fees under s. 20(1)(bb) was based on the proposition that the butterfly mechanics entailed the sale (on a rollover basis) of the shares of the Opco in question to the new public company (Novelis) in consideration for the acquisition of (subsequently redeemed) preferred shares of Novelis – so that the fees related to advice culminating in the sale or purchase of shares, as required by s. 20(1)(bb). ... The Queen, 2016 CCI 172 under s. 18(1)(a) – legal fees, s. 20(1)(g), s. 20(1)(bb), s. 20(1)(cc) and s. 14(5) – eligible capital expenditure. ...

Uber Canada – Quebec Superior Court indicates that Uber drivers, as "taxi" operators, should have QST-registered – and ARQ officials on a search could seize computers and smart phones for complete copying

9 June 2016- 8:17am Uber Canada – Quebec Superior Court indicates that Uber drivers, as "taxi" operators, should have QST-registered – and ARQ officials on a search could seize computers and smart phones for complete copying Email this Content The ARQ obtained a search warrant for searching an Uber Canada office in Montreal. ... ARQ, 2016 QCCS 2158 under ETA s. 240(1.1), ITA s. 231.3(1), General Concepts – Illegality. ...

10 October 2024 APFF Financial Strategies & Instruments Roundtable

Where the CCPC claims a foreign tax deduction under subsection 126(1) ("FTD"), a reduction is provided for in the description of B of the formula “A – B” in subparagraph (a)(i) of the definition of NERDTOH. More specifically, the reduction is equal to the amount by which the CCPC's deduction for the year under subsection 126(1) (the “FTD”) in respect of its foreign non-business income (clause (A) of element B of the “A – B” formula) exceeds 8% of the foreign investment income ("FII") (clause (B) of element B of the “A – B” formula). ... This notional calculation of 8% of FII in clause (B) of element B of the “A – B” formula applies regardless of whether a foreign country has levied a tax on foreign source income. ...

10 June 2019 Internal T.I. 2019-0796221I7 F - Qualification d’un véhicule à titre de « voiture de tourisme » -- translation

10 June 2019 Internal T.I. 2019-0796221I7 F- Qualification d’un véhicule à titre de « voiture de tourisme »-- translation ...

IC 76-12R9 – Applicable Rate of Part XIII Tax on Amounts Paid or Credited to Persons in Countries With Which Canada Has a Tax Convention

The payer can ask for relief on penalties and interest by writing to their tax services office or by submitting a completed Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties or Interest. ... (CDS) on securities registered in the name of Cede & Co. Tax on these payments is withheld by CDS based on information it receives from the Depository Trust Company (DTC) and collected by DTC participants. ... To determine whether Part XIII of the Act (available at Income Tax Act- justice.gc.ca) applies to a payment, please refer to the relevant provisions of the Act and the appropriate articles of any relevant tax convention (available at Tax treaties – canada.ca). ...

9 April 2021 GST/HST Ruling 219060 - – [Public Service Body Rebate - Whether subsidies under the] Canada Emergency Wage Subsidy (CEWS) […] [are considered] government funding […]

9 April 2021 GST/HST Ruling 219060- – [Public Service Body Rebate- Whether subsidies under the] Canada Emergency Wage Subsidy (CEWS) […] [are considered] government funding […] Unedited CRA Tags Public Service Body Rebate (GST/HST) Regulations-Section 2 Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada. ... The “Total Revenue” denominator in the above formula (A + B + C- D) refers to funding received from both public and private sources in addition to government funding. These amounts include: * government funding that is identified as such in the NPO’s financial statements * income from investments (interest and dividends) * non-capital distributions from a trust to the NPO * loans from people with whom the NPO is not dealing at arm's length (for example, an NPO funds a related NPO through loans with unusually low interest rates). ...

20 November 2017 CTF Annual Conference - Diana Aird (Justice) on Rectification & Rescission

There is nobody from the CRA on the Committee – it is just a working group of lawyers. ... Contemporaneous documents are usually going to be the most persuasive evidence you have – they are much better than someone’s recollection of whatever the tax plan was, years after the fact. ... We sometimes encounter documents that are worded very vaguely – asking us to fix the tax mistake and allowing the taxpayer to draft whole new documents, “whatever is needed.” ...

26 February 2019 Toronto CRA & Tax Professionals - International Tax

BEPS Actions 8-10 (revised transfer pricing guidelines) The working party responsible for Actions 8-10 (“Working Party Six”) was the only BEPS party to operate on a consensus basis; that is, the soft language in those Actions was essentially by design – e.g. using “may” instead of “shall.” ... We have held off until now because the financial transactions project is not finalized – there may be some big changes coming out of that. ... We do not necessarily see that as the case – our penalty regime is based on reasonable efforts. ...

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