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These are additions to our set of 2,445 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,458 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ¾ years of releases of such items by the Directorate. ...

Income Tax Act- Section 5- Subsection 5(1) salary that is forfeited by RCMP officer for misconduct nonetheless is includible as salary which was constructively received General Concepts- Payment & Receipt forfeited salary nonetheless includible as salary received ...

Topic Descriptor 17 May 2023 IFA Roundtable Q. 1, 2023-0964391C6- stock based compensation and transfer pricing Income Tax Act- Section 7- Subsection 7(3)- Paragraph 7(3)(b) s. 7(3)(b) non-deduction or s. 112(1)(e) deductibility could apply to cross-border stock option recharges of non-resident parent Income Tax Act- Section 247- New- Subsection 247(2) stock-compensation expenses may be relevant to pricing cross-border services charges even where s. 7(3)(b) prohibits their deduction 17 May 2023 IFA Roundtable Q. 2, 2023-0964301C6- Ukraine Russia FAs and Tax Reporting Income Tax Act- Section 233.5 failure to file complete information for affiliate in war-torn country Income Tax Act- Section 220- Subsection 220(2.1) potential relief from return-filing requirements re FA in war-torn country 17 May 2023 IFA Roundtable Q. 3, 2023-0964551C6- T1134 Supplement Income Tax Act- Section 233.5 T1134 should be timely-filed with missing information noted Income Tax Act- Section 90- Subsection 90(2) a pro rata distribution by an LLLP to its members is a dividend 17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Treaties- Income Tax Conventions- Article 29 Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion 17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6- Remote Work Arrangements Income Tax Act- Section 253- Paragraph 253(b) s. 253(b) does not extend to “invitation to treat” or advertisement Income Tax Act- Section 253- Paragraph 253(a) product development from Canadian home office might engage s. 253(a) Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) whether Canadian home offices of US employees can give rise to it carrying on business in Canada Treaties- Income Tax Conventions- Article 5 whether employee’s home office can constitute a PE of US employer 17 May 2023 IFA Roundtable Q. 6, 2023-0964351C6- Application of the Canada-US Treaty Treaties- Income Tax Conventions- Article 4 Treaty benefits could be created for a s. 216 structure by creating partnerships for US purposes 15 September 2020 IFA Roundtable Q. 7, 2020-0853571C6- Regulation 5901(2)(b) Pre-Acquisition Surplus Election Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b)- Subparagraph 5901(2)(b)(ii) Reg. 5901(2)(b)(ii)(A) does not taint a siloed dividend paid by FA to Canco1 even though another Canco holds other FA shares through an LP 17 May 2023 IFA Roundtable Q. 7, 2023-0964521C6- Application of Article 10, Canada-Hong Kong Treaties- Multilateral Instrument- Article 7- Article 7(1) the PPT object and purpose test is met where individuals in a Treaty country transfer their Canco shares to a Treaty-resident Holdco to reduce dividend withholding Treaties- Income Tax Conventions- Article 10 violating main purpose test in HK Treaty increases dividend rate/ PPT object and purpose test not violated by using personal holding company in same jurisdiction 17 May 2023 IFA Roundtable Q. 8, 2023-0964561C6- Tax-free Surplus Balance and Paragraph 88(1)(d) Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(d)- Subparagraph 88(1)(d)(ii)- Variable C surplus computation not required in typical bump and run transaction Income Tax Regulations- Regulation 5905- Subsection 5905(5.4) no surplus calculations needed where FA of Canadian target is acquired by Forco through a Cdn. ...

These are additions to our set of 2,577 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ¾ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2002-10-11 28 October 2002 External T.I. 2002-0134785 F- Partitioning of Shares Income Tax Act- Section 248- Subsection 248(1)- Property interest in trust is a single property even if held as units Income Tax Act- Section 248- Subsection 248(20) s. 248(20) might apply if a partition results in the issuance of whole shares Income Tax Act- Section 248- Subsection 248(21) s. 248(21) could apply to partitioning a share if the corporation could issue fractional shares on the partition satisfying the FMV test, and similarly for partitioning MFT units (viewed as a single property) Income Tax Act- Section 98- Subsection 98(3) partners not permitted to receive divided interest in shares on s. 98(3) wind-up 28 October 2002 External T.I. 2002-0117595 F- REVENU EXPERT-COMPTABLE Income Tax Act- Section 9- Nature of Income accountants required to individually recognize professional income earned by them as employees of an NPO corporation 2 October 2002 Internal T.I. 2002-0135807 F- Lumpsum Somme Forfaitaire Reg 102 / 103 Income Tax Regulations- Regulation 103- Subsection 103(4)- Paragraph 103(4)(c) withholding on retiring allowance paid in periodic instalments determined under Reg. 102(1) 25 October 2002 External T.I. 2002-0137705 F- Butterfly Income Tax Act- Section 85- Subsection 85(1)- Paragraph 85(1)(e) CCRA will permit UCC to be split on a pro rata basis under s. 85(1)(e)(i) where the butterfly entails s. 85(1) drop-downs to Newco subs of DC followed by their transfers to TCs 4 November 2002 Internal T.I. 2002-0160697 F- REPARTITION DU PLAFOND Income Tax Act- Section 125- Subsection 125(5)- Paragraph 125(5)(a) s. 125(5)(a) did not apply to a CCPC for its 2nd 2000 taxation year resulting from an acquisition of control causing it to be associated with a different CCPC 22 October 2002 External T.I. 2002-0162835 F- Recbles Recd. after Disp. of Farm. ...

Income Tax Act- Section 50- Subsection 50(1)- Paragraph 50(1)(b)- Subparagraph 50(1)(b)(iii)- Clause 50(1)(b)(iii)(A) “insolvent” means unable to pay one’s debts/ can’t be insolvent if nil liabilities and assets 25 February 2002 Internal T.I. 2001-0114167 F- DOMMAGES- DISCRIMINATION Income Tax Act- Section 248- Subsection 248(1)- Retiring Allowance compensation under the CHRA for lost wages and expenses would be a retiring allowance – reasonable (e.g., under $5,000) compensation for pain and suffering would be non-taxable Income Tax Act- Section 3- Paragraph 3(a) awards by human rights tribunals for pain and suffering re wrongful termination often are under $5,000 ...

Regarding the requirements in s. 84.1(2.31)(g) or s. 84.1(2.32)(h) for a timely transfer of business “management” to the children (specified in s. 84.1(2.3)(i) to refer to the direction or supervision of business activities) CRA stated: [W]here the parent remains a director of Parent Inc. and steps are not taken to completely and permanently cease to hold such office, within the time periods stipulated by paragraphs 84.1(2.31)(g) and 84.1(2.32)(h), including any longer period that is reasonable in the circumstances, the requirements of subparagraphs 84.1(2.31)(g)(ii) and 84.1(2.32)(h)(ii) would not be satisfied … regardless of whether the parent is the sole director or one of the directors, and regardless of whether the direction of the day-to-day activities is in the hands of the children. ...

These are additions to our set of 3,005 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 3,024 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ...