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2 November 2023 APFF Roundtable Q. 2, 2023-0982751C6- Meaning of purpose tests in paragraph 55(2.1)-- summary under Paragraph 55(2.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) the payment of a pre-closing dividend of significant excluded assets by the target to its parent likely would engage s. 55(2) where no safe income A corporation resident in Canada ("Parent") owning 100% of "Target" accepts an offer from an unrelated third party ("Purchaser") to purchase all of the Target shares for $3 million, with the sale agreement specifying that assets which Purchaser does not wish to acquire ("Excluded Assets") are assigned a value of zero. ...

15 May 2019 IFA Roundtable Q. 2, 2019-0798751C6- Shared workspaces and PE-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 a Canadian shared-work space can readily constitute a PE In the following examples, will a U.S. resident carrying on business in Canada, be considered to be a permanent establishment (“PE”) in Canada, assuming Arts. ... Example 2 The fact that another entity owns the shared workspace is not important to the PE analysis – it is enough that the shared workspace is at the non-resident’s disposal. ...

Situation 1 – If Individual A had designated three siblings as equal beneficiaries under the FHSA in accordance with provincial law, would each sibling be required to report $10,000 in Year 2? Situation 2 – If Individual A’s estate had been designated as beneficiary under the FHSA in accordance with provincial law, would it be required to report $30,000 in Year 2? ... CRA then indicated that, on the assumption that, under the provincial law, the beneficiaries under the FHSA were the siblings in Situation 1, and the estate in Situations 2 and 3, there would be an inclusion in such beneficiaries’ income pursuant to s. 146.6(17)(c). ...

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. ...

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.” ...

26 May 2016 IFA Roundtable Q. 2, 2016-0642061C6- AOA & Notional Expenses-- summary under Article 7 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 7 no deduction of notional expenses from the profits of PEs of (non-U.S.) non-residents Notwithstanding the new wording of Article 7 of the OECD Model Convention and the OECD commentary thereon, CRA continues to consider (in light of Cudd Pressure and s. 4(b) of the Income Tax Conventions Interpretations Act) that notional expenses are not deductible in computing the profits attributable to a Canadian permanent establishment for Treaty purposes – with the exception of PEs of qualifying U.S. residents, as to which there is an agreement with the U.S. competent authority which overrides s. 4(b) of the ITCIA. ... Summary of 26 May 2016 IFA Roundtable, Q. 2 under Treaties – Art. 7. ...

7 October 2016 APFF Roundtable Q. 2, 2016-0652841C6 F- Changement partiel d’usage- immeuble locatif et résidentiel-- summary under Principal Residence Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence triplex contained separate housing units An individual owner of the whole triplex used Unit 1 (representing 50% of the area) for direct personal use and rented out the other two units – then some years later (at the beginning of “Year 11”), started renting out Unit 1, moved into Unit 2 for direct personal use and provided Unit 3 to family members at a low rent. ...

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 2, 2022-0936281C6 F- police d'assurance-vie & avantage-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) taxable benefit where 2 Holdcos pay premiums on life insurance policies of which their jointly-owned sub is beneficiary unless s. 246(2) applies Suppose that two brothers resident in Canada each have a Holdco owning 50% of Opco and that, in order to fund the buy-sell agreement on the death of an ultimate shareholder, each Holdco has purchased insurance on the life of its sole shareholder, with Opco as the revocable or irrevocable beneficiary of both insurance policies. ...

2 November 2023 APFF Roundtable Q. 1, 2023-0975421C6 F- Paragraph 25 of IT-293R (Archived)-- summary under Forgiveness of Debt Summary Under Tax Topics- Income Tax Act- Section 9- Forgiveness of Debt reversal of CRA position that forgiveness of an old trade debt generally will be on capital account IT-293R, para. 25 indicates that where the forgiveness of a trade debt occurs in a taxation year subsequent to that in which it was incurred, any portion of the forgiven debt that did not relate to inventory of merchandise on hand at the beginning of that taxation year of forgiveness will not be included in computing income pursuant to s. 9 and instead will be subject to the statutory debt-forgiveness rules summarized in para. 1 of the Bulletin. ... The change in position is applicable to debts settled or extinguished on or after November 2, 2023. ...