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The fact that the Delaware & Florida LLP or LLLP resulted from a previous conversion from an LLC would not by itself prevent accessing the grandfathering relief. ...

Summary of 29 May 2018 STEP Roundtable, Q.5 under s. 120.4(1) – excluded shares. ...

CRA indicated that the exclusion in s. 112(3.32) from the application of s. 112(3.2)(b) should apply where an estate has received an s. 84(3) deemed dividend on a redemption, it designates that dividend, distributes it to the spousal trust, and the spousal trust in turn designates and pays it to the individual beneficiary – so that the taxable dividend does not reduce the loss. ...

Summary of 12 February 2018 interpretation 167422R under ETA s. 156(1) – qualifying group. ...

DC then transferred its marketable securities to three transferee corporations (TCs) for the three beneficiaries in consideration for “butterfly shares” – but with DC holding onto the notes that it received on the immediate redemption of the butterfly shares for a redacted period of time. ...

11 July 2018- 11:35pm CRA confirms that the substituted loan exception in s. 18(9.1)(a) does not apply re a prepayment penalty incurred in refinancing with another arm’s length lender Email this Content S. 18(9.1) may deem a penalty that can reasonably be considered to relate to the amount of interest that would have been payable on a loan for subsequent taxation years to be deductible interest in those years – subject to an exception that applies where the penalty can reasonably be considered to have been made respecting the substitution of the debt obligation. ...

18 September 2018- 11:48pm CRA finds that Incoterms did not govern the place of delivery of goods for ETA purposes Email this Content Company B, a resident registrant, agreed to sell goods (the “Property”) to Company C, an unregistered non-resident, using the Incoterms® 2010 DAP Port of Liverpool, U.K. so that delivery and title transfer was to occur at the U.K. destination – although the parties agreed that Company C was to indemnify Company B if the Property were lost or damaged in transit. ...

4 October 2018- 12:06am CRA suspends its proposal to impose advantage tax, where RRSP or TFSA fees are paid by the annuitant or holder, pending a Finance review Email this Content In 29 November 2016 CTF Roundtable Q. 5, 2016-0670801C6, CRA indicated that the payment of fees for investment management of an RRSP, RRIF or TFSA by the plan annuitant or holder typically would now be considered as an “advantage” giving rise to tax under s. 207.05(1) equal to 100% of the fee amount (noting inter alia under the hypothetical arm’s length test in s. 207.01(1) – advantage- (b)(i) that it would not be “commercially reasonable for an arm’s length party to gratuitously pay the expenses of another party”)- but that it would defer applying this new position until January 1, 2018 (subsequently extended by 2017-0722391E5 to January 1, 2019). ...

Summary of 2 November 2018 External T.I. 2018-0771851E5 under s. 120.4(1) – reasonable return. ...

CRA has now stretched s. 40(3.5)(c)(i) even further, and found that it applies if the CFA is wound-up into its three shareholders, having regard to ss. 33(2) and 3(1) of the Interpretation Act ("Words in the singular include the plural … unless a contrary intention appears. ...