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BEPS Actions 8-10 (revised transfer pricing guidelines) The working party responsible for Actions 8-10 (“Working Party Six”) was the only BEPS party to operate on a consensus basis; that is, the soft language in those Actions was essentially by design – e.g. using “may” instead of “shall.” ... We have held off until now because the financial transactions project is not finalized – there may be some big changes coming out of that. ... We do not necessarily see that as the case – our penalty regime is based on reasonable efforts. ...

Email this Content 26 November 2013 Annual CTF Roundtable Q. 1 ("Pre-ruling consultations") Notes from Presentation Q. 2 ("Upstream loans") Q. 2(a) – Repayment of upstream loans Notes from Presentation Official Response Q. 2(b)(i) – Repayment of upstream loans – Back-to-back loans Notes from Presentation Summary of Written Response Official Response Q. 2(b)(ii) – Repayment of upstream loans – Back-to-back loans Notes from Presentation Summary of Written Response Official Response Q. 3 ("CAE Inc. ... Q. 4(b) – T1135/T1134 – No e-filing/ T1135-extension of normal reassessment period Notes from Presentation Electronic filing of T1134s and T1135s has not yet arrived. ... The obligations — much like needed repairs to property — are a future cost embedded in the forest tenure that serves to depress the tenure’s value at the time of sale. ...

Email this Content 2020 IFA-YIN Seminar on COVID-19 Guidelines Q.1 — Whether "Travel Restrictions" Must Be Enforceable Q.2 — Meaning of "Solely as a Result" Q.3 — Individual Not Ordinarily Resident in Canada Q.4 — Non-Resident Employers Q.5 — Directors Forced to Stay in Canada Q.6 — Location of Board Meetings Q.7 — Applicability to Residence in Other Jurisdictions Q.8 — Competent Authority Tie-Breaker Rule Q.9 — Non-Treaty Countries Q.10 — Non-resident corporation's return obligation Q.11 — S. 253(b) test during COVID Q.12 — TPM-17 and COVID government assistance Q.13 — Contacting CRA Q.14 — Waiver and Clearance Certificates Q.15 — CEWS and bad debts/discounts Q.16 — Convertible debentures Q.17 — Cameco This summarizes CRA responses at a webinar hosted by the International Fiscal Association (Canadian Branch) on 6 August 2020 (a Young Members Event). ... Would the presence of an employee in Canada — with or without the approval of their employer — be a situation in which the employer is considered to be carrying on business in Canada pursuant to paragraph 253(b) of the ITA? ... Q.16 — Convertible debentures Is there any update on the CRA’s administrative position on convertible debt as expressed in 2013-0509061C6 Part XIII Tax & Standard Convertible Debentures? ...

Email this Content 29 May 2018 STEP Roundtable Q.1 — Update on the Dedicated Telephone Service Preliminary Response Official response Q.2 — Creation of a Trust Preliminary Response Official response Q.3 — Trust return due date in the year of wind up Preliminary Response Official response Q.4 — Safe Income and an Estate Preliminary Response Official response Q.5 — Split Income Proposals- Definitions Preliminary Response Official response Q.6 — Split Income Proposals- Holding company qualifying as "excluded share" Preliminary Response Official response Q.7 — Split Income Proposals- Excluded shares and business income Preliminary Response Official response Q.8 — Subsection 70(5) Preliminary Response Official response Q.9 — Requirements for a trust to have all interests in the trust vest indefeasibly Preliminary Response Official response Q.10 — Pipeline Rulings Preliminary Response Official response Q.11 — Trusts subject to subsection 104(13.4) in year of death of the trust's primary beneficiary Preliminary Response Official response Q.12 — U.S. ... The test in proposed s. 120.4(1) – “excluded shares” – (a)(i) is that business income be less than 90% from the provision of services. ... Preliminary Response Phil Kohnen: In s. 108(1) – “trust” – (g), there is an exception to, among other things, the 21-year deemed disposition rule in s. 104(4). ...

Email this Content 21 November 2017 CTF Annual Conference Roundtable Q.1 – S. 107(2) distribution by resident trust to Canco owned by non-resident Preliminary response Official response Q.2 – Trusts and principal residence exemption Preliminary response Official response Q.3 – S. 55(2.1) “purpose” CRA response- Background Q.3(a) Purpose v. result Preliminary response Q.3(b) Objective v. subjective Preliminary response Official response Q.4 – S. 55(2) – Timing of deemed capital gain Q.4(a) Timing of gain Q.4(b) CDA Preliminary response Official response Q.5 – Interaction of ss. 55(5)(f) and 55(2.3) with s. 55(2.1) Q.5(a) Separate test Preliminary response Q.5(b) Stock dividend Preliminary response Official response Q.6 – Circular Pt. IV/55(2) calculations Preliminary response Official response Q.7 – CRA Folios update Preliminary response Official response Q.8 – MLI “principal purpose test” Q.8(a) GAAR Committee Preliminary response Q.8(b) PPT/GAAR Preliminary response Q.8(c) GAAR jurisprudence Preliminary response Q.8(d) OECD examples Preliminary response Official response Q.9 – Stock option deduction Preliminary response Official response Q.10 – Tax shelter rulings Preliminary response Official response Q.11 – Application of Art. ... This is not a new position – I refer you to 2012-0440191R3. Official response 21 November 2017 CTF Roundtable Q. 10, 2017-0724291C6- Tax Shelters Q.11 – Application of Art. ...

Email this Content 25 November 2021 CTF Roundtable Q.1 – Indemnities and Subsection 87(4) Preliminary Response Scenario 1 Scenario 2 Scenario 3 Scenario 4 Official Response Q.2 – Subsection 15(2) Shareholder Loans and TOSI Preliminary Response Official Response Q.3 – Section 86.1 Preliminary Response Official Response Q.4 – “Liable to Tax” and Territorial Taxation Preliminary Response Official Response Q.5 – Corporate Attribution in a Tiered Corporate Structure Preliminary Response Official Response Q.6 – Subsection 143.4(1) and the “right to reduce” Preliminary Response Official Response Q.7 – Sub-funds and the Tracking Interest Rules Preliminary Response Scenario 1 Scenario 2 Official Response Q.8 – Loan from a FA to a Partnership held by two FAs Preliminary Response Official Response Q.9 – Work-Space-in-the-Home Expenses Preliminary Response Official Response Q.10 – Regulation 100(4)(a) and Payroll Deductions and Remittances Preliminary Response Official Response Q.11-Subsection 261(21), Loan to FA and Excluded Property Preliminary Response Official Response Q.12 – Remission Orders and Fees Preliminary Response Official Response Q.13 – Income Tax Rulings Directorate Preliminary Response Official Response Q.14 – Failure to Properly File a T1135 and Section 233. ... S. 95(8) always turns on the pool of property – referred to as the “tracked property and activities.” ... The courts have also found that there must be a link between the money that was borrowed and the current use – the “current use approach.” ...

Email this Content 25 September 2017 CTF Finance Roundtable on 18 July 2017 Proposals Passive Income Q.1 – Effect on lower-bracket taxpayers Oral Response Q.2 – Calculating deferral on investment income Oral Response Q.3 – Principles affecting the proposals Oral Response Q.4- Grandfathering Oral Response Income-Sprinkling Q.5 – Complexity of TOSI Oral Response Q.6 – Difference in treatment of family transactions Oral Response Q.7 – Comparison of friends in business vs. family members Oral Response Surplus-Stripping Q.8 – Pipeline transactions Oral Response Q.9 – Effects on intergenerational transfers of family businesses Oral Response Q.10 – Scope of s. 246.1 Oral Response Q.11 – Non-ancillary s. 246.1 application to NAL transactions Oral Response General Q.12 – Implementation Oral Response Additional comment on tax advantage computation This summarizes the oral responses provided by two senior Finance officials at the Finance Roundtable held at the Infinity Convention Centre in Ottawa on 25 September 2017. ... I do not know precisely how the legislative proposals – I’ll focus on income sprinkling for the moment – will go forward – that is to say whether the next step is another draft, tabling, or something else. ... There is also the longer term – not years, but more than the next couple of weeks or months – where we need to consider whether to add exceptions or refinements to the rules. ...

• NRCo owns Forco. Forco owns 100% of a Canadian operating subsidiary (CanOpco). ... " CRA also would need to consider the business activities of: · the CRIC; · all corporations resident in Canada with which the CRIC does not at the investment time, deal at arm's length; · the subject corporation; · all subject subsidiary corporations, as that term is described in s. 212.3(16)(a); and · all non-resident corporations with which the CRIC, at the investment time, does not deal at arm's length, other than any corporation that is, immediately before the investment time, a controlled foreign affiliate of the CRIC for the purposes of s. 17. ... Official Response 23 May 2013 IFA Round Table, Q. 6h, 2013-0483751C6 Q. 7 – Thin capitalization • Assume that a Canadian subsidiary has two loans outstanding to specified non-residents: its US Parent and a UK related company. ...

Email this Content 27 October 2020 CTF Roundtable Q.1 – ACB increase in s. 55(3)(a)/88(1) reorg Preliminary Response Official Response Q.2 – Consolidation of safe income in a corporate group Preliminary Response Official Response Q.3 – Safe Income on Reorganization Preliminary Response Official Response Q.4 – Sale of taxable Canadian property by a partnership Preliminary Response Official Response Q.5 – Art. ... Treaty where further French layer Preliminary Response Official Response Q.6 – MLI and PPT Preliminary Response Official Response Q.7 – Use of cottage by children of settlor of AET/JST/CLPT Preliminary Response Official Response Q.8 – SDA rules and formula-based appreciation plans Preliminary Response Official Response Q.9 – UK LLPs as corporations Preliminary Response Official Response Q.10- Refreezes and s. 74.4(2) attribution quantum Preliminary Response Official Response Q.11 – Refinancing prescribed rate loans and attribution Preliminary Response Official Response Q.12 – Impact of COVID-19 on Previous APAs/Current MAPs Preliminary Response Official Response Q.13 – Reimbursement of Equipment Preliminary Response Official Response Q.14 – Section 86 Reorganization of Capital Preliminary Response Official Response This provides the text of the written questions that were posed, and summaries of the CRA oral responses, at the CRA Roundtable webinar hosted on 27 October 2020 by the Canada Tax Foundation. ... Official Response 27 October 2020 CTF Roundtable Q. 4, 2020-0862451C6- Sale of TCP by a partnership Q.5 – Art. ...

Email this Content 3 December 2019 CTF Roundtable Q.1 – Application of Multilateral Instrument (MLI) PPT Preliminary Response Official Response Q.2 – Translation under s. 126 of foreign taxes paid Preliminary Response- Q.2(a) Preliminary Response- Q.2(b) Official Response Q.3 – Translation of s. s. 55(5)(d)(i) TFSB at SIDT Preliminary Response Official Response Q.4- Ss. 84.1(1)(b) and 129(1)(a) Preliminary Response Official Response Q.5- S. 212.1(6) and post-mortem pipelines Preliminary Response Official Response Q.6- Distribution of TCP by resident trust to NR-owned corporate beneficiary Preliminary Response Official Response Q.7 – S. 120.4(1.1)(b)(ii) where share distribution by inter vivos trust on death Background – before Mr. ... In Scenario 1, the exchange rate of the US dollar is US $1 = CDN $1 at Time 1 and US $1 = CDN $1.2 at Time 2 At Time 2 Can Opco pays a dividend of $120 to Can Holdco In Scenario 2, the exchange rate of the US dollar is US $1 = CDN $1.2 at Time 1 and US $1 = CDN $1 at Time 2 At Time 2 Can Opco pays a dividend of $100 to Can Holdco. ... This implies a degree of correlation or direct substitution – one might say a “causal relationship” – between the disposition of the former property and the acquisition of the new one. ...