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10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4 CRA Tags Treaties Article XXIV 126(7) "non-business-income tax" 20(11) Treaties Article V Principal Issues: What credits and deductions are available to U.S. citizens resident in Canada on taxes paid in respect of dividend income now that rates have increased in conjunction with the "fiscal cliff". ... Reasons: Text of the treaty. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 4. ...

10 June 2013 Roundtable, 2013-0480411C6- STEP Roundtable – June 2013- Question 10 Principal Issues: Deductibility of probate and related fees by an estate. Position: Question of fact Reasons: In our view, the Tax Court of Canada's decision under the informal procedure was based on the unique facts of the case. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 10. ...

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution CRA Tags 93(2) 93(2.01) Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to shares owned by a taxpayer in respect of which the taxpayer made a capital contribution consisting of shares of another foreign affiliate? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 7 – Subsection 93(2.01) substituted property rule and capital contributions Assume the following hypothetical facts: a) Canco owns all of the shares of each of FA1 and FA2. b) Canco capitalizes FA1 with $1,000 of equity. c) FA1 loans $1,000 to FA2 for use in its active business. d) A few years later, after having paid dividends of $50 to Canco, FA1 becomes a wholly-owned subsidiary of FA2 as a result of a contribution of capital by Canco of the shares of FA1 to FA2. ...

13 February 2017 Roundtable, 2017-0684491C6- CPA-BC & CRA Roundtable 2017 Principal Issues: Whether the CRA will re-introduce a dedicated phone line for tax professionals. ... CPA-BC & CRA Roundtable 2017 Question 16: We were very excited about the introduction of the CRA’s “professional designated phone line”, only to find out that this was meant for small practitioners who have no tax advisers. ...

25 September 2012 CTF Roundtable Q. 4, 2012-0457581C6- CTF BC – Q4 Residency of a Trust Principal Issues: Impact on the CRA published position in relation to the factors it considers indicative for purposes of establishing residency of a trust in light of the 2012 SCC decision in St. ... Reasons: Comments as previously published by the Directorate British Columbia Tax Conference September 25, 2012 Question 4 – Residency of a Trust for Tax Purposes CRA's long-standing position on the determination of the residency of a trust for tax purposes is described in IT-447 Residence of a Trust or Estate (published in 1980). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c) CRA Tags 93.2 Principal Issues: Whether paragraph 95(2)(c) applies in a situation where a taxpayer transfers shares of a foreign affiliate to another foreign affiliate that is a “non-resident corporation without share capital”, within the meaning of subsection 93.2(1), without any “shares” being issued as consideration? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 10 – Interaction of section 93.2 and paragraph 95(2)(c) It is our understanding that subsection 93.2(3) was introduced with the specific purpose of facilitating the application of paragraph 95(2)(c), among other provisions, to “non-resident corporations without share capital”, within the meaning of subsection 93.2(1). ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election CRA Tags 108(1) Principal Issues: 1. ... STEP CRA Roundtable – June 10, 2016 Question 4. Qualified Disability Trust and Preferred Beneficiary Election There are a number of conditions that must be met in order for a trust to be eligible to be a Qualified Disability Trust (“QDT”) for a particular tax year. ...

7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6- TOSI & Meaning of Excluded Business Unedited CRA Tags 120.4 Principal Issues: Whether dividend income earned by a spouse who works as a part-time receptionist in the business would be subject to TOSI. ... Reasons: See below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 4. ...

8 July 2020 CALU Roundtable Q. 3, 2020-0842151C6- Insurance Proceeds & CDA Unedited CRA Tags "capital dividend account" defn in ss. 89(1); s. 148; ss. 248(1), Reg. 306, Reg.1401(3) Principal Issues: Whether the "fund value" portion of a payment made under an exempt single-life life insurance policy by an insurer to a corporation as a consequence of the death of the life insured under the policy is "proceeds of life insurance" for purposes of subparagraph (d)(ii) of the definition of capital dividend account in subsection 89(1). ... The scheme of these rules generally provide for the taxation of amounts received by a policyholder out of the policy prior to the death of the life insured under the policy, but on a tax-free basis where they are paid out as a consequence of the death of the life insured. 2020 CALU CRA Roundtable – July 2020 Question 3- Proceeds of an Insurance Policy and Calculation of the CDA credit Background One of the death benefit patterns permitted under a Universal Life (UL) policy is often referred to as “face amount plus fund value”. ...

5 May 2021 IFA Roundtable Q. 3, 2021-0888281C6- IFA 2021 Q.3: 247(3)- C$5 M Threshold & 261(5) Unedited CRA Tags 247(3), 261(5)(b), 261(5)(c). ... Reasons: Interpretation of the Act. 2021 International Fiscal Association Conference CRA Roundtable Question 3 – Application of subsection 261(5) to the $5M threshold of subsection 247(3) Assume that a Canadian corporation (“Canco”) with an “elected functional currency”, within the meaning of subsection 261(1), is subject to “transfer pricing income adjustments”, as defined in subsection 247(1), in respect of a “functional currency year”, as per the meaning of that expression under subsection 261(1). ...