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2 December 2010 External T.I. 2010-0376451E5 F- Paragraphe 69(11) et transfert de biens agricoles-- summary under Subsection 70(9) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(9) s. 70(9.01) could apply to devise of farming property, that was farmed by father but not sons, to them Upon the death of their father (Mr. ... Alternatively (in Scenario 2), Son A carried on the farming business for a number of years before Mr. ... After summarizing the conditions in s. 70(9), CRA stated: Provided that the conditions for the application of subsection 70(9) are satisfied, we are of the view that, in both Scenario 1 and Scenario 2, the transfer of Mr. ...

2 December 2010 External T.I. 2010-0376451E5 F- Paragraphe 69(11) et transfert de biens agricoles-- summary under Subsection 69(11) Summary Under Tax Topics- Income Tax Act- Section 69- Subsection 69(11) s. 69(11) could apply where devisee sells qualified farm property shortly after receiving it under s. 70(9.01) Upon the death of their father (Mr. ... Alternatively (in Scenario 2), Son A carried on the farming business for a number of years before Mr. ... Specifically, in Scenario 1, it is possible that this provision applies because of the subsequent sale by both sons, while in Scenario 2, it could apply because of the subsequent disposition by Son B. ...

2 February 2018 Internal T.I. 2017-0728331I7- Central paymaster- partnership-- summary under Subsection 402.1(5) Summary Under Tax Topics- Income Tax Regulations- Regulation 402.1- Subsection 402.1(5) application of the paymaster rules to salaries paid by a partnership A partnership is the legal employer, with Corp 1 having a 30% partnership interest, and Corp 2 having a 70% partnership interest. ... In addition, under subsection 402.1(3) … the amount of salaries and wages paid in a taxation year by the partnership employer that is deemed to be paid by the benefiting corporation is deducted from the partnership employer’s salaries and wages paid in the taxation year. … As a result, for the purposes of subsection 402(6), the salaries and wages paid that are allocated to the members of the partnership (Corp 1 and Corp 2) would not include the salaries and wages paid that are deemed by subsection 402.1(3) to be paid by the benefiting corporation. ...

26 March 2001 External T.I. 2001-0070165 F- Conventions fiscales et lois provinciales-- summary under Article 2 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 2 Canada has no obligation to absorb Quebec taxes imposed on property income with treaty-reduced withholding Where a Quebec resident who was resident in a treaty country under the tie-breaker rule was otherwise subject to both Quebec tax and Part XIII tax on property income received from Quebec, the ARQ had suggested that Canada should reduce its rate of withholding to 0%. CCRA stated: Canadian tax treaties only cover “the taxes imposed by the Government of Canada under the Income Tax Act” (see, for example, paragraph 2 of Article II of the Canada-United States Tax Convention). ...

28 January 1999 Internal T.I. 9902047- DISPOSITION OF CLASS 13 LEASEHOLD INTEREST-- summary under Section 2 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule III- Section 2 Because the amount of CCA which is deductible in respect of Class 13 is not reduced for subsequent taxation years when a disposition of a Class 13 property occurs (because the amount of CCA is determined on a lease by lease basis), the impact of a disposition of a leasehold interest may be substantially deferred. ...

26 November 2020 STEP Roundtable Q. 2, 2020-0840001C6- Subsection 104(13.4) and LCBs-- summary under Subsection 161(1) Summary Under Tax Topics- Income Tax Act- Section 161- Subsection 161(1) s. 104(13.4)(c) extension of balance-due date for terminal stub year of alter ego/joint spousal trust can permit capital loss in subsequent stub year to eliminate terminal year interest The death of the settlor of an alter ego trust, or the death of the survivor of spouses for a joint spousal trust, on July 31 triggers (under s. 104(13.4)(a)) a year end and the commencement of a subsequent taxation year ending on December 31. ... The taxable capital gain reported in the return filed on that date for the 1 st taxation year (filed on that date) shows a capital gain (that arose on the death under s. 104(4)(a)) equalling a capital loss that in fact was realized in the 2 nd taxation year (the return for which is filed at the same time). CRA indicated that the loss carryback requested on the form T3A filed with the 2 nd return will not be processed concurrently with the T3 return for 1 st taxation year, as the loss must first be recognized by CRA before it can be applied to the earlier taxation year – so that the initial notice of assessment for the 1 st taxation year would not reflect the carryback, and would show interest owing where the computed balance of tax owing was not paid on or before March 31. ...

2 June 2011 External T.I. 2011-0399501E5- TCP distributed by N/R trust to N/R beneficiary-- summary under Subsection 107(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(2) A non-resident inter vivos trust distributes its shares of a private Canadian real estate corporation (Canco) in satisfaction of the capital interest of its sole non-resident benficiary. S. 107(2.1) rather than (2) applied: [S]ubsection 107(2) is not applicable in this case because the shares of Canco would not qualify as property described in any of subparagraphs 128.1(4)(b)(i) to (iii). ...

2 December 1993 Memorandum 933330 (C.T.O. "Non-Resident Exercise Stock Option (4093-U5-100-15)")-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 A detailed example showing how a stock option benefit ultimately realized by a U.S.-resident individual is allocated among his years of employment in Canada, and the exemption in paragraph 2 of Article 15 of the Canada-U.S. ...

10 June 2013 STEP Canada Roundtable, 2013-0480271C6- Prescribed Rate Loan- 2013 STEP Roundtable Q 2-- summary under Subsection 74.5(2) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(2) locking in prescribed rate Can the interest rate on a loan to a spouse or other family member remain fixed at the current prescribed rate of 1% (so that there is no income attribution) where the loan is a demand loan with no term, or it has a term of say 20 years? CRA stated: Income and gains will not be attributed to the transferor (pursuant to subsections 74.1(1) and (2), and section 74.2) if the loan is set at the prescribed rate "at the time the indebtedness was incurred" as stated in subsections 74.5(1) and 74.5(2). ...

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.3, 2016-0674821C6 F- Individuals separated living under the same roof-- summary under Common-Law Partner Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Common-Law Partner meaning of living "separate and apart" CRA accepts the family law jurisprudence that former spouses or common-law partners can potentially qualify as living separate and apart even if they are living under the same roof (e.g., pending sale of the house), and cited the criteria in M. v. H, [1999] 2 S.C.R. 3 of “shared shelter, sexual and personal behaviour, services rendered between them, social activities and relations, economic support and children, as well as the societal perception of the couple.” ...