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9 November 2016- 12:39am CRA confirms that the application of s. 75(2) to only one property in a trust can taint all the other trust property under s. 107(4.1) Email this Content CRA confirmed that a personal trust was tainted under s. 107(4.1) when it was settled with a gold coin by one of the capital beneficiaries – so that until the settlor died, none of the other property in the trust could be rolled out under s. 107(2) to the other capital beneficiaries even though such property had been acquired in an arm’s length purchase from an arm’s length vendor. ...

B on an intestacy – would not result in any of the grandchildren receiving proceeds of disposition, and that such distribution would occur under s. 107(2). ...

Summary of S2-F1-C2, Retiring Allowances under s. 248(1) – retiring allowance. ...

15 November 2016- 11:41pm CRA considers that farm quota units often are identical properties for determining their cost as Class 14.1 assets Email this Content CRA considers that since “in most cases, units of a particular type of farm quota are indistinguishable from one another,” the units (viewed as Class 14.1 properties) likely would constitute identical property whose cost is averaged under general principles or under s. 47 – including where their cost is determined under the transitional rule in draft s. 13(38)(b)(ii) based on the pre-2017 eligible capital expenditure made for their acquisition. ...

-dollar denominated debenture is converted into shares, stating that a loss from appreciation in the shares of the issuer is not an FX loss described in s. 39(2) – and also indicated that if a similar case arose, it would consider that s. 143.3(3)(b) also denied a loss respecting the share appreciation. ...

Summary of 28 October 2016 Interpretation 152996 under ETA s. 123(1) – office. ...

Summary of 6 December 2016 External T.I. 2014-0542551E5 under s. 248(1)- taxable Canadian property – (d). ...

Summary of May 2016 Alberta CPA Roundtable, Q.18 under s. 248(1)- graduated rate estate – para. ...

Summary of 24 February 2017 External T.I. 2016-0669081E5 under s. 233.3(1) – reporting entity. ...

Summary of 14 March 2017 External T.I. 2016-0656101E5 Tr under s. 248(1) – death benefit. ...