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IV tax under s. 186(1)(b) – a tax deferral. Suppose, instead, that on March 31, being a day that Opco and Bankco are not connected, a dividend is paid both by Opco to the trust, and by the trust to Bankco – but on September 30, a share ownership change results in Opco and Bankco now being connected, so that CRA’s position suggests that Pt. ...

27 January 2021- 11:06pm CRA states that the will-directed formation by a GRE of a charitable remainder trust cannot benefit the deceased’s terminal return under s. 118.1(5.1)(b) Email this Content S. 118.1(5.1)(b), when read together with the s. 118.1(1)- “total charitable gifts” – (c)(i)(C) definition, generally indicates that a gift by a graduated rate estate made within 5 years of the deceased’s death can be deemed to be a gift made by the deceased if the gift was of (i) property that was acquired by the GRE on and as a consequence of the death or (ii) property that is substituted for that property Suppose that the terms of a charitable remainder trust (“CRT”), created by the will of the deceased taxpayer to hold property of the deceased received by the GRE, provide for all the income earned by the CRT to be paid to the surviving spouse and, on the death of that spouse, for the property to be transferred to a qualified donee. ... Since the equitable interest of the donee arose at the moment of the creation of the trust, CRA did not construe there to be a gift of substituted property by the GRE (or of the remainder interest itself) – so that s. 118.1(5.1)(b) did not apply. ...

IV tax to the payees aggregating $138,333 – but this is allocated between them pro rata to the respective dividends, i.e., Pt. ... Summary of Marie-Pier Maheux, “Dividend Payment Trap: ERDTOH Converted to NERDTOH,” Canadian Tax Focus, Vol. 11, No. 1, February 2021, p. 3 under s. 129(4)- eligible refundable dividend tax on hand – subpara. ...

Regarding the safe income attributable to the shares at the conclusion of these transactions, it indicated that, since the loan was “was repaid out of the corporation's earned or realized income … that income cannot be viewed as contributing to the unrealized gain on the common shares of the capital stock of Opco” – so that the relevant safe income attributable to the 50% shareholding in Opco of each of the two Holdcos was $100,000- $50,0000, or $50,000. ...

Furthermore, the math in the formula is wrong – even if it were effective, it would only eliminate the deduction at taxable capital levels of $510 million, not $15 million. ... Summary of Allan Lanthier, “Tax relief for family business transfers: A legislative fiasco” – Part I, Canadian Accountant, 8 July 2021 and Part II, Canadian Accountant, 9 July 2021 under s. 84.1(2)(e). ...

Summaries of GST/HST Memorandum 17-11 [17.11] Determining Whether a Financial Institution is a Qualifying Institution for Purposes of Section 141.02 23 July 2021 under s. 141.02(1) – qualifying institution, residual input tax amount, tax credit amount, s. 141.02(4), s. 141.02(9), s. 141.02(24), Input Tax Credit Allocation Methods (GST/HST) Regulations, s. 1 – bank, insurer. ...

Additional points made include: A mooted spouse trust is disqualified by the existence of a power to encroach on the capital or income for the benefit of persons other than the spouse or common-law partner, prior to their death – or by a discretion of the trustee to allocate the trust’s income or capital among members of the deceased taxpayer’s family during the life of such spouse/partner. ... Summaries of Folio S6-F4-C1, “Testamentary Spouse or Common-law Partner Trusts,” 3 February 2022 under s. 70(6)(b), s. 70(6.2), s. 248(1)- Common-Law Partner, s. 248(9.1), s. 108(3), s. 70(8)(c), s.70(7), s. 70(6.1), Treaties – Income Tax Conventions- Art. 29 B and s. 104(13.4)(b.1). ...

(b)(ii), the rental income was derived from property that was used or held principally for the purpose of gaining or producing income from an active business: [T]here are arguments to support the contention that the building used 65% by ABC Inc. in its manufacturing activities could be a property used or held primarily to earn income from its manufacturing business for the purposes of subparagraph (b)(ii) …. ... Summary of 7 October 2022 APFF Federal Roundtable, Q.12 under s. 129(4) – “income.” ...

However, practical solutions to these types of technical issues exist and therefore the CRA does not consider that a flexible approach is necessary in the[se] circumstances …. ... A mechanical application of the “in contemplation of” extension of “series” in s. 248(1) under Copthorne would suggest that a subsequent payment of a dividend out of such safe income would take that safe income into account and, therefore, would necessarily be part of the same series – so that these words provide some encouragement that CRA can apply the “series” concept more narrowly than this. ...

In this regard, CRA stated that the workers likely would regard their stay as a “transient” one and, due to the cramped accommodation, would not “view it as a place where a person is … intended to settle into or maintain an ordinary mode of living.” ... Summaries of 22 March 2022 GST/HST Interpretation 238955 under ETA s. 191(3), s. 123(1) – residential complex and s. 141(4). ...