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Official Response 15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Q.2- Withholding if swap mismatches A Canadian resident taxpayer (Canco) enters into a Swap Agreement (Swap Agreement) with a non-arm’s length non-resident company (NRco). ... This is where the wage subsidy – we’ll say $10 in this case – would be taken into account. ... Subpara (ii) describes other circumstances where distributions can be traced to the initial investment – in this case, the shares of FA1. ...

D & D Livestock What is the CRA's position regarding [D & D Livestock] which allowed a taxpayer to take into account twice the amount of the "safe income" in the context of subsection 55(2) of the ITA? ... The advance rulings consultation process started slowly – only 6 or 7 in the first 9 months. In the last 3 months there were 21 files – 17 of them concluded. In 9 of them the taxpayers were told “no way.” ...

Although s. 107(2) is not applicable to this situation, consideration could be given to whether s. 248(1) – “disposition” – (f) or s. 107.4(3) could apply to allow the property to be transferred on a tax-deferred basis. ... In other words, whether or not a s. 256(9) election is made, the "?" ... Alternatively, if you do elect out, you will not get a roll-in on the transfer in – it will be at fair market value, and the trust will not have a deemed disposition or year-end on the death of the settlor. ...

Q.2b – CRA guidance on PPT Lori Carruthers: Given that each situation is likely to be unique, we again recommend Advance Income Tax Ruling as the best source of certainty. ... Q.2c – Expedited rulings Lori Carruthers: No, we will not commit to an expedited basis, although we are sensitive to the need for all taxpayers to receive a response to a ruling request as quickly as possible, and we are working towards that. ... CRA will consider a request for relief in the form of extensions and waivers of penalties on a case-by-case basis – although I would expect that the Minister will require more than “they just shortened the deadline from 15 to six months!” ...

Of course, disputes will still happen – just look at the Trump tax-reforms in the US. ... It’s the same thing with the litigators – it’s something that auditor teams can have on request. ... Michael O’Connor – Does that include drafts of working papers? Gord Parr – Generally the final documents will suffice. ...

C’s income pursuant to s.104(13) would be considered to be US-source income – and we assume this throughout the rest of the answer. ... In many cases, however, the terms of the trust that is affected by subsection 75(2) will not have any amounts paid or payable to the contributor / settlor and ultimately the taxation of the applicable amounts in the contributor / settlor’s hands is only because of subsection 75(2) and not subsection 104(6). Accordingly, when preparing the accounting records for the trust, the subsection 75(2) attributed amounts are not recorded as being paid or payable to the contributor / settlor since the facts of the particular case will often not require the actual payment of such amounts to the contributor / settlor. ...

Of particular relevance to this specific question is the definition of “advantage” in 207.01(1) – advantage- (b)(i). ... They are the main sources of referrals to the Committee – although the Committee also considers advance income tax ruling requests on the GAAR. ... LLC that is a foreign affiliate and has a single member which is a regarded U.S. corporation should compute its “earnings” in accordance with Reg. 5907(1) – earnings- s. ...

The length of time would have to be appropriate, so there is no set period of time – it depends on the circumstances as to which period should be considered to make the determination. ... There is a common theme with the two prior responses – crypto is subject to the same obligations of keeping proper supporting documentation, in respect of crypto asset transactions. ... The discretionary relief has to be requested in prescribed form – RC4288. ...

To make a request to cancel penalties or interest, businesses or their authorized representatives should fill out Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties or Interest. ... Q.21- Court Cases / Objections Please provide an update on recent and current court cases and objections. ...

Meaning of "trust & loan corporation" CRA Comments Q.20. ... Meaning of "trust & loan corporation" Summary of Question A person whose principal activity is purchasing debt securities is a listed financial institution. ... QST administration by the Canada Revenue Agency: Quebec SLFI’S Summary of Question Pension entities with more than 90 % of their members in Quebec and less than 10% of their members in another province became Quebec SLFIs under the new Quebec Sales Tax ("QST") regime as of January 1st 2013. ...