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These (and the other full-text translations covering the last 3 ¾ years of CRA releases) are subject to the usual (3 working weeks per month) paywall. ...

12 February 2018- 11:29pm Five full-text translations from 2013 APFF Roundtable are available Email this Content The table below provides descriptors and links for five items from the October 2013 APFF Roundtable, as fully translated by us – as well as for the two French Ministerial letters released last week (which essentially repeat previously-released letters.) ...

These (and the other full-text translations covering the last 4 ¼ years of CRA releases) are subject to the usual (3 working weeks per month) paywall. ...

This policy is generally less favourable than that in (cancelled) IT-160R3 under which, for example, the benefit could be computed based on the cost of a first-class ticket in a wider range of circumstances (and for a “small, inexpensive aircraft,” might be based on an economy class fare) – and there was no mention of an imputed available-for-use benefit based on the aircraft’s cost. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2013-05-15 28 March 2013 External T.I. 2012-0460481E5 F- Allocation pour usage d'un véhicule à moteur Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b)- Subparagraph 6(1)(b)(x) fixed allowance of $4.60 for each trip under 10 kilometres deemed unreasonable 13 February 2013 External T.I. 2011-0430921E5 F- S. 261- Loss carry-back & loss carry-forward Income Tax Act- Section 261- Subsection 261(12) conversion to U.S. dollar and back again changed non-capital losses Income Tax Act- Section 261- Subsection 261(15) carryback of non-capital loss following revocation of functional currency election to functional currency year 28 March 2013 External T.I. 2012-0460031E5 F- Prime pour partager chambre à deux Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) allowance paid by 3rd-party customer to employees re double-occupancy rooms was taxable Income Tax Regulations- Regulation 200- Subsection 200(1) T4As to be issued by employer for allowance paid by 3rd-party customer to employees 2 April 2013 External T.I. 2013-0478221E5 F- CIAPH- acquisition pour une somme nominale Income Tax Act- Section 118.05- Subsection 118.05(3) purchase for nominal consideration still generates the credit 19 March 2013 External T.I. 2012-0444001E5 F- Dépenses d'adoption lors de démarches abandonnées Income Tax Act- Section 118.01- Subsection 118.01(1)- Eligible Adoption Expense expenses must be incurred in relation to successfully-adopted child 11 March 2013 External T.I. 2012-0469231E5 F- Deferred terminal loss Income Tax Act- Section 13- Subsection 13(21.2) notional properties fall in same class so that losses suspended until triggering events for all properties/ordering of dispositions to affiliated and unaffiliated transferees generally not relevant Income Tax Act- Section 13- Subsection 13(21.1)- Paragraph 13(21.1)(a) s. 13(21.1)(a) adjusts the proceeds as determined under s. 85 ...

However, that safe income amount will be split between the two classes of shares held by Trust A and Trust B based on the unrealized gain on each class – and, as noted, there now is significant unrealized gain on the preferred shares. ...

Convention 5 October 2012 Roundtable, 2012-0454131C6 F- Caractère raisonnable d'une allocation automobile Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) reasonable car allowance potentially can exceed Reg. 7306 levels/Treasury Board rates will be accepted 5 October 2012 Roundtable, 2012-0453201C6 F- Règles d'attribution- séparation & décès Income Tax Act- Section 74.5- Subsection 74.5(3) s. 74.5(3) busting of attribution occurs even if they were living separate and apart for under 90 days before the death to the transferee common-law spouse Income Tax Act- Section 13- Subsection 13(1) recapture from rental property is property income from that property ...

S. 129(1.2) could apply to deny the dividend refund if one of the main reasons for step 3(b) was to obtain a dividend refund Re GAAR, what arguably is the Lipson doctrine, that a specific anti-avoidance provision should not be used to generate a tax benefit, is bothersome (see also Satoma) Speaking of GAAR, it would appear that continuing a CCPC under foreign corporate law in order to avoid the high corporate rate on investment income is not abusive given inter alia that the scheme of the Act is to make it hard to be a CCPC rather than going in the opposite direction – and furthermore, the Department of Finance turned its mind to extending the refundable tax regime to non-CCPC private corporations in July 2017, but so far has not moved on this. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2018-12-12 5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 7, 2018-0761511C6 F- Rollover to spousal trust on death Income Tax Act- Section 70- Subsection 70(6)- Paragraph 70(6)(b)- Subparagraph 70(6)(b)(ii) tainting effect of the payment by a spousal trust of premiums on its policy on the lives of the children 5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 8, 2018-0761541C6 F- HBP withdrawals straddling two calendar years Income Tax Act- Section 146.01- Subsection 146.01(2)- Paragraph 146.01(2)(d) factors considering in extending period for making backdated withdrawals 5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F- Attribution rules and promissory note General Concepts- Payment & Receipt promissory note could not be issued as payment in context of income attribution rules Income Tax Act- Section 74.5- Subsection 74.5(2)- Paragraph 74.5(2)(b) accrued interest cannot be “paid” for s. 74.7 purposes by issuing a promissory note 5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 11, 2018-0761571C6 F- Missing info on disposition of principal residence Income Tax Act- Section 54- Principal Residence- Paragraph (c) CRA is only waiving penalties for late-filed principal residence dispositions for 2017 and 2016 returns Income Tax Act- Section 40- Subsection 40(2)- Paragraph 40(2)(b) description of filing requirements 5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 12, 2018-0761581C6 F- Foreign Tax Credits related to mutual funds Income Tax Act- Section 126- Subsection 126(1) CRA is no longer requesting country-by-country breakdowns of income derived from mutual funds in its FTC audits 2012-12-24 5 October 2012 Roundtable, 2012-0451291C6 F- Subsection 85(1) and UMIR Marketplace Rules Income Tax Act- Section 85- Subsection 85(1) s. 85(1) no available where shares transferred to holding company through the exchange 5 October 2012 Roundtable, 2012-0453941C6 F- Principal residence owned by a trust-exemption Income Tax Act- Section 54- Principal Residence- Paragraph (c.1) status based on s. 248(25) application and actual habitation Income Tax Act- Section 54- Principal Residence- Paragraph (f) renunciation by specified beneficiaries immediately before sale would not affect para. ...

14 January 2019- 11:36pm 6 further translations of CRA interpretations are available Email this Content We have published another 6 translations of CRA interpretations – one of which was released last week and the others in December and November 2012. ...