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Email this Content 5 May 2021 IFA Roundtable Q.1 – COVID 19 and CRA Guidance Post September 2020 CRA Response Official Response Q.2- Multilateral Instrument (“MLI”) CRA Response Q.3 – Application of subsection 261(5) to the $5M threshold of subsection 247(3) CRA Response Official Response Q.4 – Section 247 Post Cameco FCA decision CRA Response Official Response Q.5 – Applicability of subsection 247(7) CRA Response Official Response Q.6 – Arbitration CRA Response Q.7- Section 247, FAPI and Subsection 80.4(2) CRA Response Official Response Q.8- Application of 90(9)(b)&(c) CRA Response Q.9 – Income Tax Rulings Directorate – Remissions CRA Response Official Response Please note that the following questions and answers are not official and are subject to change until they are published by CRA. ... Cameco Corporation, 2020 FCA 112 upholding the Tax Court of Canada’s decision (“ Cameco ”)? ... Q.9 – Income Tax Rulings Directorate – Remissions The fees charged by the CRA for providing an advance income tax ruling or a supplemental ruling (“Ruling”), and a consultation in advance of a Ruling (“Pre-ruling Consultation”), are governed by the Service Fees Act. ...

Email this Content 28 May 2015 IFA Roundtable Question 1 – George Weston: hedging impact Notes From Presentation Official Response Question 2- GAAR and treaty shopping Notes From Presentation Official Response Question 3 – Entity classification/LLLPs Notes From Presentation Official Response Question 4 – Upstream loans: s. 90(9) deduction Part A Part B Part C Notes From Presentation Official Response Question 5 – Back-to-back loans: “because” test Notes From Presentation Official Response Question 6 – s. 95(2)(a)(ii)(D) and contribution of capital Notes From Presentation Official Response Question 7 – FA mergers and deficit double counting Notes From Presentation Official Response Question 8 – S. 39(2.1) and s. 261(10) inclusion Notes From Presentation Official Response Question 9 – s. 95(2)(i) re purchase note Notes From Presentation Official Response Question 10 – 111(4)(e) step-up and 212.3(2) Notes From Presentation Official Response Question 11 – FA borrows to pay dividend Notes From Presentation Official Response Question 12 – Conflicting versions of Swiss Treaty Notes From Presentation Official Response Presentation by Phil Halvorson (of Finance until 1 May 2015, but in a non-representative capacity) on BEPS Question 1 – George Weston: hedging impact The Tax Court of Canada recently rendered its decision in the George Weston Ltd. ... Official Response 28 May 2015 IFA Roundtable, Q. 9, 2015-0581581C6 Question 10 – 111(4)(e) step-up and 212.3(2) Following an acquisition of control, paragraph 111(4)(e) permits a taxpayer to make a designation in respect of certain capital property in order to deem a disposition and reacquisition of that capital property. ... Official Response 28 May 2015 IFA Roundtable, Q. 10, 2015-0581641C6 Question 11 – FA borrows to pay dividend Paragraph 95(2)(a) of the Act re-characterizes, in various circumstances, amounts that would otherwise be income from property of a foreign affiliate as income from an active business. ...

Tax on Split Income – Excluded Shares CRA Response Q6. Tax on Split Income – Business Sale CRA Response Q7. ... Change in FMV – NRRPR CRA Response Q11. CRA My Business Account – View filed numbers CRA Response Q12. ... RC4188 – What you should know about audits, and IC98-1R7 – Tax Collections Policies. ...

Email this Content 15 May 2024 IFA Roundtable Q.1 – PPT and Treaty threshold for 5% withholding Preliminary Response Q.2 – Entity classification of Lux. SCS and SCSp Preliminary Response Q.3 – Cash pooling arrangements and notifiable transactions Q.3(a) Preliminary Response Q.3(b) Preliminary Response Q.3(c) Preliminary Response Q.3(d) Preliminary Response Q.3(e) Preliminary Response Q.3(f) Preliminary Response Q.3(g) Preliminary Response Q.4 – Procedure for late-filed PLOI election Preliminary Response Q.5 – Late-filed PLOI election and statute-barring Preliminary Response Q.6 – Blanket PLOI election Preliminary Response Q.7 – PPT and reduced dividend withholding Situation (a): Same Rate Situation (b): Non-Treaty Country in Ownership Chain Preliminary Response Situation (a) Situation (b) This provides the text of written questions that were posed, and summaries of the CRA oral responses, at the CRA Roundtable held on May 15, 2024 at the International Fiscal Association (Canadian Chapter) conference in Montreal. ... There are two segments in that description – thin capitalization and Part XIII tax. ...

Voluntary disclosures – wash transactions and section 236.1 CRA Comments Q.3. ... Voluntary disclosure – tax services offices CRA Comments Q.6. Voluntary disclosures – 10 YEAR RULE CRA Comments Q.7. ... FOREIGN SEMINARS – ARE SERVICES IN PART IN CANADA Summary of Facts / Background A US Company, registered for GST, provides seminars in the US. ...

HST place of supply rules – legal services CRA Comments Q.25. HST place of supply rules – sales of tangible personal property CRA Comments Q.26. ... Summary of Facts A supplier (“ Québec Co. ”) manufactures widgets for its customer (“ Ontario Co. ”). ... Une de ces conditions est que le fournisseur « possède des preuves, que le ministre estime acceptables, de l’exportation du bien par l’acquéreur ». ...

Those shares would not qualify as shares of a “ specified class ”, in particular because of paragraph 256(1.1)(b), which requires that the shares not carry voting rights. ... Official Response 10 October 2024 APFF Roundtable Q. 8, 2024-1028891C6 F- Définition du terme « automobile » Q.9 – S. 13(5.2) application to optioned automobile An individual, after having paid $12,500 in lease expenses during the first 48 months of an automobile lease, exercises the option under the lease to acquire the automobile for $15,000, at a time that its FMV is $20,000, then immediately sells it for $20,000. ... CRA Responses (a) Essentially, section 67.3 limits all or part of the “actual lease charges ” paid or payable for a passenger vehicle that a taxpayer may deduct in computing income for the year. ...

Additionally, the Progress Tracker which is available in My Account and My Business Account, provides taxpayers with the date that the objection was assigned to an appeals officer for the low & medium-complexity, ITA & GST categories. ... Q.14(e) Would the CRA consider adding to My Account / My Business Account / Represent a Client the ability to request assistance with issues that cannot be done directly online? ... Q.19(b)- Time for “T” slips to appear in My Account / Represent a Client Members have noted long delays for slips to appear on My Account / Represent a Client. ...

Email this Content 17 May 2023 IFA Roundtable Q.1 – Cross-border charges re stock-based compensation Preliminary Response Q.2 – Ukraine/Russia reporting requirements Preliminary Response Q.3 – T1134 disclosure of dividends Preliminary Response Q.4 “Special tax benefit” exclusion under Barbados Treaty Preliminary Response Q.5 – Canadian home offices and US employers Preliminary Response Q.6- Art. ... Where goods are produced or services are performed – again, this will be affected by the nature of the individual’s activities and USco’s business will be relevant in weighing this factor. ... S. 253(a) deems USco to be carrying out business in Canada if it “produces, grows, mines, creates, manufactures, fabricates, improves, packs, preserves or constructs, in whole or in part, anything in Canada ….” ...

Email this Content 15 May 2019 IFA Roundtable Q.1 – Thin cap effect of contribution by non-shareholder Summary of Preliminary Response Official response Q.2- Shared workspaces as PEs Summary of Preliminary Response Example 1 Example 2 Official response Q.3 – Participating interest and the Canada-U.S. ... Official response 15 May 2019 IFA Roundtable Q. 2, 2019-0798751C6- Shared workspaces and PE Q.3 – Participating interest and the Canada-U.S. ... It is expected to have adequately documented those efforts at the time of that determination – i.e. before the normal deadline for filing the election. ...