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28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference CRA Tags 104(4)(a) 70(5) Principal Issues: Estate Freeze Valuation of Shares. ... Reasons: See below. 2010 CTF Conference – November 28, 2010 Value of Vote-Only Shares – Question 17 Question: At the 2009 British Columbia Tax Conference the CRA stated that in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of the estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, the CRA generally accepts not to take into account any premium that could be attributable to such shares for the purposes of subsection 70(5). ... Response — The CRA does not have an established position on valuing different types of property. ...

15 June 2022 STEP Roundtable Q. 13, 2022-0929381C6- 164(6) – Amending Deceased’s Final T1 Return Unedited CRA Tags 164(3)(d); 164(5)(d),(i),(j) and (k); 164(6) Principal Issues: 1. ... Paragraphs 164(5)(d), (i), (j) and (k) apply for the purpose of the interest refund rules in subsection 164(3) and deem the overpayment to have arisen on the day that is 30 days after the latest of these three days. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 13. Subsection 164(6) – Amending Deceased’s Final T1 Return Subsection 164(6) of the Act (footnote 1) allows capital losses of a graduated rate estate in its first taxation year to be considered capital losses of the deceased, where all required conditions are met. ...

20 June 2023 STEP Roundtable Q. 3, 2023-0968091C6- Trust Reporting – Definition of Money and Treatment of Dividend Receivable Unedited CRA Tags 150(1); 150(1.1); 150(1.2)(b); ITR 204.2 Principal Issues: 1) Whether settlement items such as collectible gold/silver coins and bars would be considered “money” for the purposes of paragraph 150(1.2)(b)? ... Reasons: 1) Ordinary meaning of the term "money". 2) The law. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 3. Trust Reporting – Definition of Money and Treatment of Dividend Receivable Pursuant to paragraph 150(1.2)(b) of the Income Tax Act (Canada) (the “Act”) (footnote 1), subsection 150(1.1) can apply to a trust for a particular tax year where, the trust holds assets with a fair market value that does not exceed $50,000 throughout the year, if the only assets held by the trust throughout the year are one or more of (i) money, (ii) a debt obligation described in paragraph (a) of the definition fully exempt interest in subsection 212(3), (iii) a share, debt obligation or right listed on a designated stock exchange, (iv) a share of the capital stock of a mutual fund corporation, (v) a unit of a mutual fund trust (vi) an interest in a related segregated fund trust (within the meaning assigned by paragraph 138.? ...

15 May 2019 IFA Roundtable Q. 3, 2019-0798741C6- Participating Debt Interest & US Treaty Unedited CRA Tags 212(1)(b)(ii), 212(3) “participating debt interest”; Art. ... Under the Canada-US Tax Convention (the “Treaty”) however, interest paid by a resident of Canada to a resident of the United States that is entitled to the benefits of the Treaty is not subject to Canadian withholding tax, other than interest: “arising in Canada that is determined with reference to receipts, sales, income, profits or other cash flow of the debtor (…), to any change in the value of any property of the debtor (…) or to any dividend, partnership distribution or similar payment made by the debtor...” ... Yannick Roulier / Nicolas Bilodeau 2019-079874 May 15, 2019 ...

20 June 2023 STEP Roundtable Q. 4, 2023-0968111C6- Trust Reporting – Definition of Beneficiary Unedited CRA Tags 204.2 Principal Issues: Does subsection 204.2(1) of the Income Tax Regulations apply to a contingent beneficiary? ... Reasons: Question of the relevant facts and law. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 4. Trust Reporting – Definition of Beneficiary Pursuant to paragraph 204.2(1)(a) of the Income Tax Regulations (the “Regulations”), a trustee of a trust (unless the trust is subject to one of the exceptions in subsection 150(1.2) of the Income Tax Act (the “Act”) (footnote 1)) is to report information about each beneficiary of the trust, subject to subsection 204.2(2) of the Regulations. ...

14 September 2017 Roundtable, 2017-0703921C6- 2017 CPA Alberta Q25: Estates – Income Paid or Payable Unedited CRA Tags 104(13), 104(24), 104(6) Principal Issues: 1. ... Question of fact and law. 2017 CPA Alberta Roundtable Question 25- Estates – Income Paid or Payable An individual’s will commonly provides for his or her estate, or the residue thereof, to pass to one or more beneficiaries in fixed proportions. ... Response CRA Response (a) – (c) The CRA has previously noted that pursuant to subsection 104(6) there may be deducted in computing the income of an estate or trust for a taxation year, such amount as the estate or trust claims that would be its income for the year as became payable in the year to a beneficiary. ...

18 June 2015 STEP Roundtable Q. 8, 2015-0581961C6- 2015 STEP – Q8- Foreign entity classification Principal Issues: Does CRA keep a list of foreign entities that it generally considers to be trusts. ... STEP CRA Roundtable – June 18, 2015 Question 8. Foreign Entity Classification The case of Sommerer highlighted the need for practitioners to carefully consider the issue of foreign entity classification when dealing with foreign legal entities / relationships. ...

26 May 2016 IFA Roundtable Q. 2, 2016-0642061C6- AOA & Notional Expenses CRA Tags Treaties Article VII Principal Issues: Whether notional expenses determined under the AOA and attributable to a taxpayer’s permanent establishment in Canada can be deducted for Canadian tax purposes? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 2 – Authorized OECD Approach to Profit Attribution The possibility of deducting notional expenses in determining the profits attributable to a permanent establishment (“PE”) of a non-resident under Canada’s tax treaties was seemingly put to bed by the 1998 decision of the Federal Court of Appeal in Cudd Pressure (footnote 1). ... In respect of the Canada – United Kingdom Tax Convention, we would note that the new AOA-based Article 7 language was included in the convention by virtue of the protocol signed on July 21, 2014. ...

STEP CRA Roundtable – June 18, 2015 Question 14. Requirements for Question #6 on page 2 of the T3 Return Question 6 of the T3 return reads as follows: Did the trust borrow money, or incur a debt, in a non-arm's length transaction since June 18, 1971? ... The instructions for question 6 refer the reader to Interpretation Bulletin IT-406R2 – Tax Payable by an Inter Vivos Trust (the "IT"). ... Reference may be made to Folio S1-F5-C1 – Related persons and dealing at arm's length, for discussion as to the meaning of the term "at arm's length". ...

LLPs & LLLPs CRA Tags 248(1) "corporation" Principal Issues: Whether LLPs and LLLPs governed by the laws of Florida or Delaware would generally be treated as corporations for the purposes of the Act? ... Reasons: The provisions of the foreign legislation and the articles creating these entities support the general conclusion that these types of entities should generally be treated as corporations for the purposes of the Act. 2016 International Fiscal Association Conference CRA Roundtable Question 1 – Entity Classification: U.S. ... The main factors we considered in our analysis of these entities are the existence of a separate legal personality that is recognized under the law of the relevant foreign jurisdiction – meaning the full legal capacity to acquire and own property, to sue and be sued, to carry on their own activities and to incur liabilities of their own – and the extensive limitation of liability afforded to all of their members. ...