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Summary of 2015 Ruling 2014-0552871R3 under s. 55(1) – distribution. ...

2 October 2016- 11:31pm CRA indicates that it would not apply a correction in its position on a retroactive basis Email this Content In a French technical interpretation released in the spring, which we did not translate until now, CRA noted that in 2013-0490901I7 it had reversed its position in 2001-0113237, in finding that the Ontario Healthy Homes Renovation Tax Credit did not reduce the amount which could be claimed as a medical expenses tax credit – and then accepted that the same more favourable position applied to the similar Quebec Tax Credit for Home-Support Services for Seniors. ...

Hybrid Financing – A Canadian Perspective on the U.S. Debt-Equity Regs,” Tax Notes International, 26 September 2016, p. 1151 under s. 95(2)(a)(ii) and s. 20(1)(c). ...

8 October 2016- 11:44pm CRA indicates that loan advances to a limited partner may give rise to negative ACB gains Email this Content Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at the beginning of the following year the LP effects a distribution of the applicable share of the previous year’s profits to the limited partner by issuing a demand note to the limited partner and pays that note by way of set-off against the loans owing by the limited partner. ...

The submission also illustrates the uncertainty regarding potential circularity arising in connection with late capital dividend elections: after the generation of a full dividend refund on a dividend paid to an individual so that the paying Holdco becomes subject to a s. 55(2) capital gain, a late s. 83(2) election is made to convert part of the dividend into a capital dividend based on s. 55(2) having generated a capital gain – but this reduces the amount of the s. 55(2) gain. ...

The 2016 IFA Roundtable dealt with a contribution Canco made to a foreign subsidiary (FA2) of its shares of a non-resident Finco subsidiary (FA1 – which previously had paid exempt dividends to Canco). ...

., the sale was not an arm’s length transaction)– but also found that s. 84.1 did not apply to a purchase of shares in the same CCPC under a similarly structured transaction from the other major shareholder, as they each were advancing their own interests (arranging an exit on advantageous terms, and acquiring control of the CCPC, respectively) – so that it was an arm’s length transaction. ...

For example, if FA Opco with exempt surplus of $300 and held by FA Holdco with an exempt deficit of $100, makes two successive loans of $100 to Canco (Holdco’s parent), no reserve would be available to Canco because, each time, the $100 deemed exempt surplus dividend received by Holdco would merely eliminate its exempt deficit – notwithstanding that the consolidated surplus equals the loan amounts. ...

More interestingly, CRA also considers that the individual would have the option of treating the LLC as a source of property income in that year (being potential dividend income – and even though no dividend was ever actually received before the winding up), so that the individual would be entitled to instead deduct the U.S. income taxes in computing property income under s. 20(12), even though no deduction under s. 20(12) is permitted respecting a capital gain. ...

. … [W]here an employee sleeps in the truck cab, it is unlikely that the allowances for accommodation expenses in the three scenarios provided will be considered reasonable for the purposes of paragraph 6(1)(b). ...