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7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6- TOSI & Meaning of Excluded Business-- summary under Paragraph 120.4(1.1)(a) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1.1)- Paragraph 120.4(1.1)(a) spouse on achieving 20-hour threshold could receive large dividends as excluded amounts The spouse (the “Spouse”) of a professional (the “Individual”) owns non-voting preferred shares of his professional corporation (“XCo”) and works at least 20 hours per week as a part-time receptionist. ... CRA indicated that if Spouse works for XCo at least 20 hours per week throughout the portion of the year that the business operates, that would satisfy s. 120.4(1.1)(a), and the dividend income received by Spouse would be considered to be an excluded amount because it is derived from an excluded business – so that it would not be subject to the tax on split income. ...

7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6- TOSI & Meaning of Excluded Business-- summary under Excluded Business Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Business an excluded amount can exceed arm’s length remuneration for the services rendered The spouse of a professional works over 20 hours per week as a part-time receptionist in the professional practice of his corporation (XCo). ... CRA indicated since she satisfies the 20 hours per week test in s. 120.4(1.1)(a), her dividend income would be an excluded amount because it is derived from an excluded business – so that it would not be subject to the tax on split income. ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subsection 12(2.2) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(2.2) s.12(2.2) election can be made re s. 12(1)(x)(iv) inclusion for forgivable CEBA loan The Canada Emergency Business Account (“CEBA”) program provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... A taxpayer not qualifying for the 25% forgiveness who settles the loan for 100% of the principal may generally claim a deduction under s. 20(1)(hh) equalling the previous s. 12(1)(x) inclusion – even where the taxpayer made the s. 12(2.2) election. ...

2021 Ruling 2021-0876671R3- Transfer between US pension plans-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan S. 56(1)(a) generally requires the recognition of an amount received as or in satisfaction of a pension benefit. ...

15 March 2019 External T.I. 2018-0766021E5- Obligation to prepare T4A slips-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt the payer is the person who has discretion and control over the funds A Canadian university agreed with a (perhaps, foreign) Ministry to apply funding received by it to pay the tuition of and a monthly stipend to trainees who were accepted into a University program. ...

7 November 2022 External T.I. 2022-0926091E5- Transfer of UK DB pension benefits to a UK SIPP-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt doctrine applied to direct payment from one UK pension plan to UK individual pension plan After a UK resident (under age 55) became resident in Canada, the commuted value of the individual’s member benefits under a UK defined-benefit pension plan was transferred directly to a UK self-invested personal pension plan (SIPP) of which the individual was the sole beneficiary. ...

28 September 2023 CLHIA Roundtable Q. 1, 2023-0971701C6- Life insurance – contractual changes-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(9)- Disposition a no-cost endorsement to a life insurance policy to add benefits could be a disposition Regarding whether an endorsement to provide a new benefit under an in-force exempt life insurance policy for no cost and without any underwriting requirement, to a defined set of policyholders, would constitute a disposition, CRA stated: [I]t is necessary to determine whether the changes that are made to the terms of the policy, including but not limited to endorsements providing additional benefits, are so fundamental as to go to the root of the policy. ... [This] is a mixed question of fact and law …. ...

2023 Ruling 2023-0964601R3- Loss consolidation arrangement-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in-house re-circulating daylight loan used to fund a loss-shifting transaction CRA ruled on routine transactions between two Lossco subsidiaries and one Profitco subsidiary of an immediate Canadian parent company involving Lossco loans to the Profitco and Profitco subscriptions for Lossco cumulative preferred shares. ...

7 May 2024 CALU Roundtable Q. 8, 2024-1007121C6- IPPs & Past Service Contributions-- summary under Subsection 8303(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 8303- Subsection 8303(6) a RRIF may not make a Reg. 8303(6) qualifying transfer to a RPP in connection with a past service event Where an individual pension plan (IPP) as defined in Reg. 8300(1) is established and a plan member is age 71 in the effective year of the plan, would CRA allow the qualifying transfer which is required as part of a past service contribution (typically satisfied by a transfer of the required asset value from a registered retirement savings plan) to be satisfied by the transfer of the required asset value from a registered retirement income fund (RRIF)? ... A transfer of property from a RRIF to a defined benefit provision of a registered pension plan (including an IPP) is not a qualifying transfer for purposes of [Reg.] 8303(6) …. ...

25 January 2010 Internal T.I. 2009-0319951I7- Article 15 & definition of permanent establishment-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 PE to be determined under treaty of residence of employee rather than employer ACo is a British company that performed seismic surveys offshore Canada. ... Respecting the Norwegian and Netherlands treaties, CRA stated: Paragraph 1 of Article 21 of the Canada-Norway Treaty- Offshore Activities states that Article 21 applies notwithstanding any other provision of the treaty. … Subparagraph 5(a) of Article 21 states that…remuneration derived by an employee who is resident in Norway in respect of employment connected with the exploration or exploitation of the seabed and subsoil and their natural resources situated in Canada may be taxed in Canada, but only if the employment exceeds 30 days in any 12-month period. Therefore, if the employment exceeds 30 days, remuneration paid by BCo to employees who are resident in Norway may be taxed in Canada. … Paragraph 3 of Article 23 [of the Netherlands Treaty] provides…that "an enterprise of one of the States" will be deemed to be carrying on business in Canada through a permanent establishment if the enterprise carries on Offshore Activities in Canada for more than 30 days in any 12 month period. ...