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We have communicated this interpretation in our publication, “T4061 NR4 – Non-Resident Tax Withholding, Remitting, and Reporting” under the section, “NR4 Slips”. ... Part c) We will review and update the information in our publication, “T4061 NR4 – Non- Resident Tax Withholding, Remitting, and Reporting” to clarify and strengthen the NR4 reporting requirements, where necessary. ... Q.25 Estates – Income Paid or Payable An individual’s will commonly provides for his estate, or the residue thereof, to pass to one or more beneficiaries in fixed proportions. ...

Tax is paid of $30, with after-tax income of $70 – so that the corporation is in the hole by $30. ... Situation 1: One-wing split-up – arm’s length This slide illustrates the same thing. ... The same answer is reached – that there is no change. Situation 2: One-wing split-up – related group Prud'Homme: Again, there is again a one-wing split-up, but this time in a related group. ...

D] of the partnership [ABCD LLP] in a taxation year and is […] a shareholder of the CCPC who holds a direct interest [Mr. ... Official response 5 October 2018 APFF Roundtable Q. 8, 2018-0768791C6 F- Frais de repas Q.9 Split income exclusion for “excluded shares” (a) 2018 STEP Roundtable Q.6 and Q.7 confirmed that the shares of a holding company (or of a company generating no business income) cannot qualify as excluded shares, whereas Examples 8 to 12 of CRA’s “ Guidance on the application of the split income rules for adults ” and the Department of Finance’s “ Technical Backgrounder on Measures to Address Income Sprinkling ” provide that such shares so qualify. ... X – 20% each; and Child X and Y – 5% each). Holdco generated $150,000 from investing these funds in the stock market and paid a $100,000 dividend pro rata to its shareholders with Trust, in turn, distributing its $50,000 dividend to Mrs. ...

There were a number of things raised by the Joint Committee – for example, common share stock dividends, which you have not been able to address. ... All these positions are based on one thing – what is the scope of the deeming rule in s. 55(2)? ... Official response 27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business Q.11- Tax accrual working papers The CRA has a published position regarding its authority and process for obtaining taxpayer records. ...

X – and instead must waive the entire net tax calculation for the period. ... No CRA Written Comments Q.33 Court Cases / Objections Please provide an update on recent and current court cases and objections. ... At the Tax Court, the appellant argued that as CIBC “was deemed to be a non-resident person in respect of […] the activities […] carried on through” its foreign branches (ss. 132(3) of the Act), it could not be a party to the joint election insofar as the supplies made to the branches are concerned. ...

Investment Plans that are SLFIs – Notices of Objection and Rebates Summary of Question CRA Response Q.8. ... Selected Listed Financial Institution – Rebate of PVAT Summary of Question CRA Response Q.29. ... Recognition of nominee/prête-nom Summary of Question TVQ16-30/R1 « Contrat de prête-nom » states: “All persons may hold property of others under a nominee agreement. ...

For more information about how to obtain an advance income tax ruling or technical interpretation from the Income Tax Rulings Directorate, see the CRA’s Information Circular IC70-6R11, Advance Income Tax Rulings and Technical Interpretations³. ¹ GOVERNMENT OF CANADA, Dedicated telephone service for income tax service providers: How to register, (online: https://www.canada.ca/en/revenue-agency/services/tax/tax-professionals/dedicated-telephone-service.html) ² GOVERNMENT OF CANADA, Contact the Canada Revenue Agency (online: https://www.canada.ca/en/revenueagency/corporate/contact-information.html) ³ GOVERNMENT OF CANADA, IC70-6R11 Advance Income Tax Rulings and Technical Interpretations (online: https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/ic70-6/ic70-6-advance-income-tax-rulings-and-technicalinterpretations.html) GST – AUDIT Question Type: Admin/Process Question The legislation is very clear in section 296 of the ETA that the Minster shall assess allowable credits as part of net tax when these are discovered, both ITCs and rebates. ... PROCESSING DELAYS Question Type: Admin/Process Question What is causing the delays in processing slips in the My Account / RAC system? ... The possible answers seem to be: (a) The AII will be available on the entire cost of the asset on its completion – it is considered “acquired” in its entirety only when it is completed (b) The AII will not be available if construction of the asset commenced prior to November 21, 2018 – it was considered “acquired” when construction commenced. ...

New Charitable Donation Rules – Part 1 Scenario 1 [dividends as substituted property?] ... New Charitable Donation Rules – Part 2 Oral Response Summary Official Response Q13. ... However, can the CRA provide specific guidance with respect to paragraph 5 of Article XXIX of the Canada – US treaty? ...

Base erosion – services (ss.95(2)(b)(ii)) Question Notes from Presentation CRA Response Written Response Q9. 95(6)(b) – post Lehigh Question Notes from Presentation CRA Response Written Response Q10. ... See summary under s. 248(1) – derivative forward agreement. Written Response 2 December 2014 CTF Conference Q. 1, 2014-0546701C6 Q1. ...

Email this Content 2022 Alberta CPA Roundtable Q.1- Dealing with CRA on Assessments and Reassessments Q.1(a) CRA Comments Q.1(b) CRA Comments Q.1(c) CRA Comments Q.1(d) & (c) CRA Comments 2. ... Q.1(d) & (c) d) What is the best approach to resolve these issues? ... Response d) & e): CRA Comments Providing all the supporting documentation and clearly indicating the fields to adjust could help prevent issues with the requested reassessment. ...