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These are additions to our set of 1,084 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¾ years of releases of Interpretations by the Directorate. ...

These are additions to our set of 1,152 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 ½ years of releases of Interpretations by the Directorate. ...

Where the RRSP issuer is notified of the death of the annuitant after the due date for filing the T4RSP information return (at the end of February following the year of death “the issuer will be required to file an additional T4RSP … for the deceased annuitant within a reasonable time after being notified of the death.” ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2010-04-23 22 December 2009 Internal T.I. 2009-0328141I7 F- 93(2)- Perte due à fluctuation de devises Income Tax Act- Section 93- Subsection 93(2.01)- Paragraph 93(2.01)(b) relief under s. 93(2.01)(b) unavailable where matching FX gain is realized in a subsequent year Income Tax Act- Section 93- Subsection 93(2) loss under s. 93(2) includes a loss wholly attributable to a fully-hedged FX loss 2010-04-16 12 April 2010 External T.I. 2009-0327161E5 F- Revenu de location General Concepts- Ownership CRA can be bound by a counter letter rather than the apparent contract Income Tax Act- Section 3 notwithstanding Guide T4036, rental property can be rented at an arm’s length rent to related persons to generate losses if there is a source of income 1 April 2010 Internal T.I. 2009-0352611I7 F- Redressement après le délai de prescription Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) statement of incorrect income amount for spouse for s. 118(1)(a) credit purposes is a misrepresentation – but CRA must establish that prudent person would not have so erred 6 April 2010 Internal T.I. 2009-0343091I7 F- Montant pour enfant Income Tax Act- Section 118- Subsection 118(4)- Paragraph 118(4)(b) two separate parents with joint custody and separate residences can agree who claims which of their 3 children 9 April 2010 External T.I. 2010-0361381E5 F- Eligible Dividend Income Tax Act- Section 89- Subsection 89(14) dividends declared separately can be separate dividends notwithstanding their payment by one cheque ...

. … The CRA does not have its own method for computing the FMV; this computation is based upon the facts known on the valuation date, to which the principles and standards of the Canadian Institute of Chartered Business Valuators are applied. ...

These are additions to our set of 1,291 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 ¾ years of releases of Interpretations by the Directorate. ...

These are additions to our set of 1,297 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 ¾ years of releases of Interpretations by the Directorate. ...

4 November 2020- 10:51pm CRA indicates that the central management and control of a TFSA trust is generally exercised in the office of the investment firm to which most of the trustee’s functions have been delegated Email this Content When asked where a self-directed TFSA was resident, CRA indicated that the trust would always be resident where its central management and control was factually exercised by the trustee – irrespective of the level of involvement of the TFSA holder in the decisions. ...

CRA indicated that the loss carryback requested on the form T3A filed with the 2 nd return will not be processed concurrently with the T3 return for 1 st taxation year, as the loss must first be recognized by CRA before it can be applied to the earlier taxation year – so that the initial notice of assessment for the 1 st taxation year would not reflect the carryback, and would show interest owing where the computed balance of tax owing was not paid on or before March 31. ...

These are additions to our set of 1,331 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 ¼ years of releases of Interpretations by the Directorate. ...