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16 June 2014 STEP Roundtable, 2014-0526591C6- STEP CRA Roundtable – June 2014 – Question 9 CRA Tags 156 Principal Issues: Whether the CRA will continue with its practice of not assessing interest and penalties where an inter vivos trust does not make instalment payments as required under section 156. ... STEP CRA Roundtable – June 2014 QUESTION 9. Interest and Penalties on Deficient Instalments of Inter Vivos Trusts In response to question 20 at the 2010 STEP Canada National Conference, the CRA noted that under the current administrative policy, the CRA does not assess installment interest and penalties where an inter vivos trust does not make installment payments required under section 156. ...

22 September 1993 External T.I. 9304130- Direct ou indirectement — Fusion ou liquidation — Papillon Unedited CRA Tags 55(3)(b) SESSION SPÉCIALE DE L'APFF: 55(2) ET 55(3) DE LA LOI ETTRANSACTIONS PAPILLONSAPFF — 10 février 1993 Question 32 Il appert que Revenu Canada, Impôt a récemment donné une décision anticipée favorable lorsque dans le cadre d'une réorganisation papillon, la filiale de la corporation bénéficiaire du transfert est fusionnée plutôt que liquidée. ...

27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business Unedited CRA Tags 84(2), 120.4(1), 120.4(1.1), 125(7), 248(1) Principal Issues: Comparison of CRA’s response to question 7 of the 2018 STEP CRA Roundtable (2018-074403) and examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults. ... CRA Roundtable Question 10: TOSI – Excluded Shares and Related Business In question 7 of the 2018 CRA Roundtable of the Society of Trust and Estate Practitioners (“STEP”) the following question was asked: “Assume that a corporation has no business income because it derives income from property (possibly rental income from real property where the activities are not sufficient to constitute business income). ... Yet, even if it has been determined – taking into account the assumption made in Question 7 – that the shares of the capital stock of the corporation could not qualify as excluded shares, an amount received from this corporation by a specified individual would nevertheless be an excluded amount in respect of the specified individual. ...

7 November 1991 Income Tax Severed Letter- Ontario R & D Superallowance and the Quebec R & D Tax Credit Unedited CRA Tags 12(1)(x), 13(7.1), 37(1)(d), 127(11.1) Dear Sirs: Re: Ontario R & D Superallowance and the Quebec R & D Tax Credit This is in reply to your letter of August 13, 1991 concerning certain government allowances and credits provided by Ontario and Quebec. ... It is your understanding that any Ontario income tax savings resulting from "grossed up amounts" or "phantom deductions" provided by the Ontario Superallowance and OCCA are treated as follows for federal income tax purposes: * will not be regarded as an inducement that must be included in income pursuant to paragraph 12(1)(x) of the Act; * will not require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will not be regarded as government assistance and therefore will not reduce the amount that may be deducted under paragraph 37(1)(d) in respect of expenditures on scientific research and experimental development; and * will not reduce the amount of capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the amount of the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ... Furthermore, it is your understanding that any payment of tax that is deemed to be made to Quebec as a result of the Quebec Research and Development Tax Credit provisions will receive one or more of the following treatments for federal income tax purposes: * will be regarded as an inducement that must be included in computing the taxpayer's income pursuant to paragraph 12(1)(x) of the Act; * will require a taxpayer to reduce its capital cost of depreciable property pursuant to subsection 13(7.1) of the Act; * will be regarded as government assistance and therefore will reduce the amount that may be deducted under paragraph 37(1)(d) of the Act in respect of expenditures on scientific research and experimental development; and * will reduce the amount of the capital cost to, or the qualified expenditure incurred by, a taxpayer for the purpose of computing the taxpayer's investment tax credit pursuant to subsection 127(11.1) of the Act. ...

The taxpayer can direct that the funds be used at the Centre for:         A.   ... Of particular concern was the requirement in subsection 37(1)(a) of the Act that;     "... the taxpayer is entitled to exploit the results of such scientific research and experimental development... ... A Payer will be entitled to deduct from its income a contribution made in the year to a University pursuant to clause 37(1)(a)(ii)(B) of the Act, provided that the following conditions are met:          a)  the Payer carries on business in Canada in the taxation year;          b)  the funds are to be used by the University for SR&ED carried on in Canada;          c)  the SR&ED activity carried on by the University is related to the business of the Payer in the year the expenditure is made;          d)  the Payer completes and files Form T661, "Claim for Scientific Research and Experimental Development Expenditures"; and          e)  the Payer is entitled to exploit the results of the SR&ED. ...

7 February 1994 External T.I. 9309865 F- 6363-1 Foreign Affiliates / Cross-shareholdings / Surplus Unedited CRA Tags ITR 5902(2), 93(1) XXXXXXXXXX Attention:  XXXXXXXXXX Dear Sirs: RE:  Paragraph 5902(2)(a) of the Regulations to the Act This is in reply to your letter wherein you requested clarification of the operation of section 5902 of the Regulations to the Income Tax Act (the "Act") in the following hypothetical circumstances: 1)     A corporation resident in Canada ("Canco") owns 95% of the common shares of a foreign affiliate ("FA1") which in turn owns 100% of the common shares of a second foreign affiliate ("FA2"). ... Both FA1 and FA2 have exempt surplus balances in respect of Canco. 2)     Canco disposes of its shares of FA1 to a third party and elects under subsection 93(1) of the Act to have a portion of the proceeds of disposition deemed to be a dividend received on those shares. ...

16 May 1983 Income Tax Severed Letter 7-2462- [Part XII of the Income Tax Regulations ("ITR") — Royalty Trusts — Reporting of resource income and allowances] DATE: May 16, 1983 TO- COMPLIANCE DIRECTORATE Audit Programs Division FROM- CORPORATE RULINGS DIRECTORATE J.C. ... Chief Mines, Oil & Forest Industries Section Specialty Corporations Rulings Division Corporate Rulings Directorate Legislation Branch Attachment ...

9 October 2009 Roundtable, 2009-0330081C6 F- Sens de " année " au paragraphe 74.5(2) Unedited CRA Tags 74.5(2) Principales Questions: Quel sens faut-il donner à l'expression " année donnée " au paragraphe 74.5(2) pour établir le montant des intérêts payables? ... Michel Lambert (613) 957-8968 October 9, 2009 2009-033008 ENDNOTES 1 AGENCE DU REVENU DU CANADA, interprétation technique 912556, " Meaning of Particuliar Year ", 21 octobre 1991. 2 AGENCE DU REVENU DU CANADA, interprétation technique 2008-0274221I7 (E), Meaning of " year " in 74.5(2), 16 avril 2008. 3 Al. 249(1)b) L.I.R. 4 CANADA REVENUE AGENCY, technical interpretation 912556, "Meaning of Particular Year", October 21, 1991. 5 CANADA REVENUE AGENCY, technical interpretation 2008-0274221I7 (E), Meaning of "year" in 74.5(2), April 16, 2008. 6 Par. 249(1)(b) of the ITA ...

22 May 1992 Income Tax Severed Letter 9214997- Old at-risk rules — administrative position — Signum case Unedited CRA Tags 96(1) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... This led to Appeal's Decision # 89-9R dated July 9, 1991 which stated that the FCA's decision was final and binding and that any outstanding objections or appeals held in abeyance pending the outcome of this appeal must be processed. ...