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9 October 2009 Roundtable, 2009-0330081C6 F- Sens de " année " au paragraphe 74.5(2) Unedited CRA Tags 74.5(2) Principales Questions: Quel sens faut-il donner à l'expression " année donnée " au paragraphe 74.5(2) pour établir le montant des intérêts payables? ... Michel Lambert (613) 957-8968 October 9, 2009 2009-033008 ENDNOTES 1 AGENCE DU REVENU DU CANADA, interprétation technique 912556, " Meaning of Particuliar Year ", 21 octobre 1991. 2 AGENCE DU REVENU DU CANADA, interprétation technique 2008-0274221I7 (E), Meaning of " year " in 74.5(2), 16 avril 2008. 3 Al. 249(1)b) L.I.R. 4 CANADA REVENUE AGENCY, technical interpretation 912556, "Meaning of Particular Year", October 21, 1991. 5 CANADA REVENUE AGENCY, technical interpretation 2008-0274221I7 (E), Meaning of "year" in 74.5(2), April 16, 2008. 6 Par. 249(1)(b) of the ITA ...

16 June 2014 STEP Roundtable, 2014-0526591C6- STEP CRA Roundtable – June 2014 – Question 9 CRA Tags 156 Principal Issues: Whether the CRA will continue with its practice of not assessing interest and penalties where an inter vivos trust does not make instalment payments as required under section 156. ... STEP CRA Roundtable – June 2014 QUESTION 9. Interest and Penalties on Deficient Instalments of Inter Vivos Trusts In response to question 20 at the 2010 STEP Canada National Conference, the CRA noted that under the current administrative policy, the CRA does not assess installment interest and penalties where an inter vivos trust does not make installment payments required under section 156. ...

3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan Unedited CRA Tags 6(1)(a), 248(1) “private health services plan” Principal Issues: Whether a health spending account established for a sole employee-shareholder can qualify as a private health services plan. ... CALU Roundtable – May 2022 Question 10 – Private Health Services Plans Background An employer can offer its employees a Private Health Services Plan (PHSP) that takes the form of a Health Spending Account (HSA), also known as a cost-plus plan. ...

15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency Unedited CRA Tags 85; 261 Principal Issues: Whether the CRA can confirm in which currency amounts reported in form T2057 should be denominated in circumstances where section 85 applies in respect of a property transferred by a transferor that has a tax reporting currency different from that of the transferee. ... The first scenario of example 3 in paragraph 1.69 of the Folio S5-F4-C1 – Income Tax Reporting Currency (Feb. 27, 2019) provides an example of a situation where subsection 261(18) of the Act might be applicable. ...

19 November 2021 Roundtable, 2021-0914351C6- 2021 TEI Conference – Q3(b)(i) – Form T2200 Unedited CRA Tags 8(1)(i)(iii), 8(2), 8(10), 8(13), 67 Principal Issues: How the employer should complete the answers to Question 10 on Form T2200 in the case where an employee has the option to work from home and that time is not tracked by the employer? ...

8 May 2012 Roundtable, 2012-0435731C6- CALU CRA Roundtable – May 2012 – Question 5 Unedited CRA Tags ITR 8304(10), 8503(26) Principal Issues: 1. ... CALU CRA Roundtable – May 2012 Question 5 – Individual Pension Plans (IPPs) Background The 2011 federal budget contained two proposals that affect certain defined benefit IPPs. ... The IPP PSPA calculation is determined using the formula A – B. Variable A is the greater of two amounts, described in paragraphs (a) and (b) respectively. ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D) Unedited CRA Tags Clauses 95(2)(a)(ii)(B) and (D), paragraph 20(1)(c), subsection 5907(1) of the Income Tax Regulations Principal Issues: How the current use approach would apply in analyzing clauses 95(2)(a)(ii)(B) and (D) to two specific examples. ...

18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6- 2015 STEP – Q2 – Meaning of Graduated Rate Estates CRA Tags 248(1) Principal Issues: CRA comments requested on meaning of graduated rate estate, including what property is included & what happens when there are 2 wills. ...

27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business Unedited CRA Tags 84(2), 120.4(1), 120.4(1.1), 125(7), 248(1) Principal Issues: Comparison of CRA’s response to question 7 of the 2018 STEP CRA Roundtable (2018-074403) and examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults. ... CRA Roundtable Question 10: TOSI – Excluded Shares and Related Business In question 7 of the 2018 CRA Roundtable of the Society of Trust and Estate Practitioners (“STEP”) the following question was asked: “Assume that a corporation has no business income because it derives income from property (possibly rental income from real property where the activities are not sufficient to constitute business income). ... Yet, even if it has been determined – taking into account the assumption made in Question 7 – that the shares of the capital stock of the corporation could not qualify as excluded shares, an amount received from this corporation by a specified individual would nevertheless be an excluded amount in respect of the specified individual. ...

18 June 2015 STEP Roundtable Q. 15, 2015-0572151C6- 2015 STEP – Q15- Tax Audit & Net Worth Statements CRA Tags 241 231.1(1) Principal Issues: Can CRA comment on auditors requesting personal financial information and/or furnishing statements of net worth of the shareholders of Canadian corporations? ... STEP CRA Roundtable – June 18 2015 Question 15. Tax Audit and Net Worth Statements Can CRA comment on the following: a) It has come to our attention that CRA is increasingly requesting personal financial information of the shareholders of Canadian corporations which are selected for audit. ...