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Nonetheless, a Quebec general or limited partnership has many of the characteristics typically associated with legal personality such as being able or subject to suing or being sued in its own name, and having a separate patrimony – and CRA has “previously stated that the existence of a separate legal personality alone is generally not sufficient to distinguish certain foreign partnerships from Canadian partnerships.” ...

CRA indicated that such a request could be granted since it would have no impact on the tax payable for the particular year, but “emphasize[d] … that there is nothing in the Act that compels the Minister to automatically accept such requests.” ...

19 June 2024- 11:18pm CRA indicates that the TCC has confirmed its view that an amount paid by a trust to a beneficiary is not deductible under s. 104(6) if it was not payable under the trust deed Email this Content CRA referred to an unreported 2023 Tax Court decision (which has not been appealed) regarding a family trust that realized a capital gain, paid $100,000 to each of two minor beneficiaries in the same taxation year, and claimed the deduction therefor pursuant to s. 104(6)(b) – notwithstanding that the trust deed prohibited any distributions to designated persons in respect of the father. ...

25 June 2024- 11:17pm CRA indicates that a Canadian payer must withhold on rent paid to a s. 94 deemed resident trust Email this Content Regarding the application of Part XIII to a non-resident trust that is deemed to be resident in Canada pursuant to s. 94 and which owns a Canadian rental property, CRA indicated that such trust is not subject to Part XIII tax on amounts paid or credited to it, but is not considered to be resident in Canada for the purposes of determining the liability of a person other than the trust to withhold and remit under s. 215 – so that there is still a requirement for the Canadian tenant(s) to withhold and remit Part XIII tax on the rent paid by them. ...

After confirming that the reimbursements by the Canadian customer of the travel costs and meals of USCo and Cansub were not subject to Reg. 105 withholding, CRA further found that the fees paid by the Canadian customer in respect of the services performed in Canada of the subcontractor (CanSub) were subject to Reg. 105 withholding – and noted that this position would be the same even if CanSub were a non-resident of Canada. ...

Summary of 6 February 2024 Internal T.I. 2022-0936261I7 under Treaties – Art. 4. ...

. … Neal Armstrong. Summary of 2023-1000061E5 under Reg. 1104(13)- “wood waste.” ...

21 August 2024- 1:02am CRA rules on a post-mortem pipeline with a 24-month implementation timeline, and an earlier note repayment to fund terminal return taxes Email this Content CRA ruled on a straightforward post-mortem pipeline concerning the estate of the deceased- who had died holding high-ACB preferred shares of Opco and common shares and preferred shares of the Holdco holding the Opco common shares – providing for: Opco redeeming preferred shares held by the estate, giving rise to a deemed dividend and a capital loss, which the estate carried back under s. 164(6). ...

After noting that “on July 22, 2022, the Minister of Crown-Indigenous Relations announced that the section 87 tax exemption would be available for continuation on modern treaty governments’ former reserves and other First Nations reserves in Canada for prospective and existing modern treaty government beneficiaries who are registered or entitled to be registered under the Indian Act ”, CRA indicated that, pending a formal revision of Guideline 4: [T]he CRA will consider a modern treaty government that was formerly a band as defined under the Indian Act or was created to represent one or more such bands, to be an eligible employer for purposes of Guideline 4. ...

Summaries of CRA Webpage, “Excessive interest and financing expenses limitation rules,” 24 September 2024 under s. 18.2(18), s. 18.2(4), s. 18.2(16), s. 18.2(1) – specified pre-regime loss, and s. 95(2)(f.11)(ii)(E). ...