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3 May 1994 Roundtable Q. 1, 9411620- SAFE INCOME & ALBERTA ROYALTY TAX CREDITS Unedited CRA Tags 55(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues:- Alberta Royalty Tax Credits & Safe Income Position TAKEN:- treated like government assistence for purposes of safe income Reasons FOR POSITION TAKEN:- Consistent with position taken in 91 paper presented by M. ...

8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6- Qualifying person & multiple shares Unedited CRA Tags Subparagraph 2(c) of Article XXIX-A of the Canada-U.S. ... Reg. § 1.884-5(d)(4)(i)(B). Under the regulation, a class of shares is considered to be "regularly traded" if (i) trades of the class of shares are made in more than de minimis quantities on at least 60 days during the taxable year (hereafter the "de minimis test"), and (ii) the aggregate number of shares in the class traded during the year is at least 10 percent of the average number of outstanding shares during the year (hereafter the "10-percent test"). ...

3 May 2016 CALU Roundtable Q. 5, 2016-0632641C6- Clearance certificate & GRE rules Principal Issues: Will the CRA clearance certificate process be modified in situations where a clearance certificate is needed before a gift can be completed by a graduated rate estate? ... CALU Roundtable – May 2016 Question 5- Clearance Certificates and GRE rules Background Subsection 159(2) of the Act requires a legal representative of a taxpayer to obtain a clearance certificate before distributing property under the legal representative’s control. ...

14 May 2015 CLHIA Roundtable, 2015-0573841C6- 2015 CLHIA Roundtable – Winding-up and ACB CRA Tags 148(7) 88(2) 69(5) Principal Issues: Does subsection 69(5) take precedence over subsection 148(7) in respect of the distribution of an interest in a life insurance policy by a corporation to a shareholder on a subsection 88(2) wind-up of the corporation? ...

20 May 2011 Roundtable, 2011-0398491C6- CLHIA 2011- CRA & Comfort Letters Principal Issues: See Q&A Position: See Q&A Reasons: See Q&A CLHIA Roundtable- May 20, 2011 Question 9- Comfort Letters At the 2009 CTF Round Table, CRA confirmed (in question 16) its practice of accepting tax returns filed on the basis of Department of Finance comfort letters. ...

7 May 2024 CALU Roundtable Q. 8, 2024-1007121C6- IPPs & Past Service Contributions Unedited CRA Tags ITR 8303(6) Principal Issues: Whether a transfer of property from a RRIF to an IPP is a qualifying transfer for purposes of subsection 8303(6) of the Regulations? ...

12 June 2012 Roundtable, 2012-0442941C6- STEP Roundtable – June 2012- Question 4 CRA Tags 70(1) Principal Issues: (a) Whether subsection 70(1) is limited to the types of income specified therein, or does it apply generally to all items of income payable on a periodic basis? ... STEP CRA Roundtable – June 2012 QUESTION 4 Subsection 70(1) provides a rule whereby in the year of death certain sources of income are to be determined on an accrual basis. ...

25 July 2008 Roundtable, 2008-0275871C6- Form T1261 / S. 116 certificate Unedited CRA Tags 116 150 Principal Issues: June 2008 STEP Question #7- Form T1261 / Section 116 Certificate for dispositions of an interest in an estate resident in Canada. ...

8 October 2004 Roundtable, 2004-0086691C6- Rectification Orders & Annulment of Contracts Principal Issues: Whether the decision of the court in B.E.A. ... Trafsys Inc. and Trafsys Communications Inc changed the position of the CRA mentioned in Technical News # 22 with respect to rectification orders. ...

13 February 1998 Roundtable, E9731756- Subsection 20(12) & U.S. Social security tax20(12) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... February 13, 1998 Jennifer Gilmour Enquiries & Adjustments David R. ...