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26 November 2020 STEP Roundtable Q. 13, 2020-0847201C6- GRE & section 216 election Unedited CRA Tags 248(1) graduated rate estate; 216; 107(2), 107(5), 117(2). 3(1) and 33(2) of the Interpretation Act Principal Issues: 1. ... Once the beneficiaries each hold beneficial ownership of their interest in the rental property, they could meet the conditions in section 216. 2020 STEP CRA ROUNDTABLE – November 26, 2020 QUESTION 13. ...

3 December 2024 CTF Roundtable Q. 11, 2024-1038241C6- Global Minimum Tax Act – Interpretation and Application of OECD Agreed Administrative Guidance Unedited CRA Tags GMTA 3(1); 17(6); 24 Principal Issues: In the case of a reverse hybrid that is fiscally transparent in relation to an indirect owner (an FT-CE), will the CRA administer the application of the GMTA based on the June 2024 Administrative Guidance? ... This includes the application of subsection 3(1), which is described in the Department of Finance’s Explanatory notes as intending “to ensure that the Act is interpreted, applied and administered in a manner consistent with the outcomes provided under the Model Rules, Commentary and Administrative Guidance (referred to in this note, collectively, as the “Pillar Two Rules”), including any future revisions or additions to the Pillar Two Rules”. 2024 CTF Annual Tax Conference CRA Roundtable Question 11- Global Minimum Tax Act – Interpretation and Application of OECD Agreed Administrative Guidance We understand that CRA Rulings has formed a new Specialty Tax Division, in the Income Tax Rulings Directorate (the “ITRD”) of the Legislative Policy and Regulatory Affairs Branch, and that, amongst other items, this new division is responsible for interpreting the new Global Minimum Tax Act (the “GMTA”), implementing Pillar Two in Canada. ...

7 February 1994 CTF Roundtable Q. 1, 4M09660- 1993 CTF QUESTIONS & ANSWERS Unedited CRA Tags 70(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. ... The grossed-up total of withholding tax is calculated by applying the following formula: Required payment = tax rate X interest payment 100 minus tax rate For example, the required payment of withholding tax on an interest payment of $1,000, assuming a withholding rate of 15%, would be calculated as follows: 15 X $1,000 = $176.47 (100- 15) Canada-U.S. ... Business & Property Income- Paragraph 18(1)(l) Question 60 What is the Department's current assessing practice in situations similar to Sie Mac Pipeline Contractors Ltd. (93 DTC 5158)? ...

A similar fact pattern was considered in CRA document # 2015-0622751I7 (August 16, 2017). ... (ii) This answer builds on the technical interpretation provided by the CRA in document # 2015-0622751I7 that was issued in 2017. ... Vicky Liu / Nicolas Bilodeau 2021-088752 May 5, 2021 ...

30 October 2019 TEI Roundtable Q. 2, 2019-0828621C6- 2019 TEI Conference – Question 2 Principal Issues: Update regarding S2-F3-C2. ... During the approval period, the CRA continues to administer employee discounts on merchandise in accordance with the administrative policy outlined in Guide T4130, Employers Guide – Taxable Benefits and Allowances, which is currently available on the tax pages of the Canada.ca website. ...

The following example illustrates the financial statement presentation under the new rules: On January 1, 1996, Canco issues a US$100M denominated debt when the exchange rate is US$1 = CAN$1.30. ... The financial statement presentation at that date is: Asset Liability Hedge Asset $10M Hedge Debt $140M 2.On December 31, 1997, the exchange rate is US$1 = CAN$1.20. The financial statement presentation at that date is: Asset Liability Debt $120M Hedge liab. 10M 3.On December 31, 1998, the exchange rate is US$1 = CAN$1.30. ...

20 June 2023 STEP Roundtable Q. 14, 2023-0967371C6- s.70(6) & Application to Extend Principal Issues: (A) What is the process for making a written application to extend the 36 month period for property to become vested indefeasibly with the surviving spouse or common-law partner, or a testamentary spousal or common-law partner trust? ... (B) A written application should include details that provide the director of the legal representative’s tax services office with a clear picture of the reason for the extension request. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 14. ... One condition is that the deceased’s property vests indefeasibly with the surviving spouse or common-law partner, or a testamentary spousal or common-law partner trust: “…if it can be shown, within the period ending 36 months after the death of the taxpayer or, where written application therefore has been made to the Minister by the taxpayer's legal representative within that period, within such longer period as the Minister considers reasonable in the circumstances, that the property has become vested indefeasibly in the spouse or common-law partner or trust, as the case may be…” The T4011 Guide – Preparing Returns for Deceased Persons notes that if the legal representative needs more time to meet this condition, they can make a written request to the director at their tax services office before the end of the 36 month period. ...

16 June 2014 STEP Roundtable, 2014-0523091C6- STEP CRA Roundtable – June 2014 CRA Tags 248(8) 252(3) 70(6.2) 70(6) 248(1) 70(5) Principal Issues: Can the rollover provisions of subsection 70(6) apply to a transfer of property to a taxpayer's spouse and transfer of another property to a common-law partner? ... STEP CRA Roundtable – June 2014 QUESTION 1. Transfer to Spouse and Common-Law Partner A rollover is available under subsection 70(6) where property is left by a taxpayer resident in Canada to a taxpayer's spouse or common-law partner who is resident in Canada immediately before the taxpayer's death. ...

12 June 2012 June STEP Roundtable, 2012-0442681C6- STEP CRA Roundtable – June 2012- Question 2 CRA Tags 86 160(1) 160(4) 85 Principal Issues: Would 160(1) or 160(4) apply in the case of a butterfly reorganization? ... STEP CRA Roundtable – June 2012 QUESTION 2 Section 160 provides for joint and several liability between a transferor and a non-arm's length transferee where a transfer has occurred at less than fair market value. ...

28 November 2010 Roundtable, 2011-0424761C6- CTF 2010 Q&A #22- ELHTs & HWTs CRA Tags 6(1) 144.1 Principal Issues: Interaction of new ELHT regime with existing HWT regime Position: Both will exist 2010 CTF – November 28, 2010 Employee Life and Health Trusts Question 22 On August 27, 2010, the Department of Finance released revised legislative proposals to accommodate new employee benefit arrangements called employee life and health trusts (ELHTs). ...