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Various Questions Relating to T1134 Reporting (for 2021 and later taxation years) (i) Part I Section 3E – Lower tier non-controlled foreign affiliates (Table) (ii) Part II Section 1D – Foreign Affiliate Dumping Rules (Table) (iii) Part II Section 3A – Surplus Accounts – 4. ... In the situation described above, will CRA consider that UKco has a permanent establishment in Canada under Article 5 of the Canada – U.K. ... ASIC Miners ASIC miners, on the other hand, are designed and optimised to perform a single task – mine crypto-assets. ...

In this scenario – where Canada maintains full ability to tax – are the businesses, undertakings and activities of B Co carried on in Canada? ... ATI for a taxation year is determined by the formula: A + B – C, where A is determined by the formula D-E. ... One of the requirements, in paragraph 84.1(2.31)(a), is that a previous inter-generational exception to section 84.1 has not been sought out – i.e., that “the taxpayer has not previously, at any time after 2023, sought an exception to the application of subsection 84.1(1) under paragraph 84.1(2)(e) in respect of a disposition of shares …”. ...

Q.5- Transfer Pricing Memorandum TPM-17 and COVID-19 Official Response Appropriate transfer pricing treatment of the CEWS Q.6 – Subsection 212.3(9) and the GAAR Official Response Q.7 (IFA Q. 3 – IFA provided)- Regulation 5901(2)(b) Pre-Acquisition Surplus Election Official Response Q.1- Relevant currency for purposes of filing form T2057 when parties have different tax reporting currencies Where a taxpayer transfers property to another corporation on a tax-deferred basis pursuant to section 85, form T2057 must be jointly filed by the transferor and 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. ... On September 17, 2020 the CRA launched its National Business Resumption Plan – September 17, 2020 to detail the stages of the resumption of various program and corporate activities and operations that had not resumed during the CRA’s critical services phase under the Business Continuity Plan. ...

LLPs & LLLPs CRA Response Question 11: Computation of Earnings for a Disregarded U.S. ... For example, are detailed safe income computations essential in relatively simple case where there is a holdco / opco structure and no or limited differences in accounting versus taxable income? ... Poulin wanted to leave Amiante, selling his interest in it at the best price and under the most optimal possible conditions — one of which was to benefit from his capital gains deduction. ...

Email this Content 17 May 2023 IFA Roundtable- Official Response Question 1: Section 247 & Recent Changes Regarding Stock-Based Compensation CRA Response Question 2: Ukraine/Russia Reporting Requirements CRA Response Question 3: T1134 Supplement Disclosure on Dividends CRA Response Question 3(1) Question 3(2) Question 4: Canada-Barbados Income Tax Convention – “Special Tax Benefit” Question CRA Response Question 5: Canadian tax issues for U.S. resident employers of Canadian resident employees under remote work arrangements CRA Response Question 6: Application of the Canada-U.S. ... (the “Act”), as amended to the date hereof Question 1: Section 247 & Recent Changes Regarding Stock-Based Compensation CRA has traditionally not allowed inbound charges for stock option expenses incurred by related parties to be deducted by a Canadian taxpayer when the cost of such stock options is included in the cost of services provided by the related non-resident person. ... Question 4: Canada-Barbados Income Tax Convention – “Special Tax Benefit” Paragraph 3 of Article XXX (Miscellaneous Rules) of the Canada-Barbados Income Tax Convention (“the Treaty”) provides: 3. ...

Proposed s. 247(1.1) Question Headings (from Slide) Budget 2019 transfer pricing measure Intention of proposed subsection 247(1.1) Interaction of proposed subsection 247(1.1) with certain provisions in Part I of the ITA: 17(1) – amount owing by non-resident 18(1)(a) – general limitation on deductions 18(4) – thin cap rules 85(1) – rollover Response Intention of s. 247(1.1) Cook: Ted indicated that, notwithstanding a suggestion made earlier that s. 247(1.1) was intended to increase transfer-pricing adjustments penalties, that was not the case. ... The second step is to apply Part I – s. 17 in this case. Consider a Canco holding a non-interest-bearing loan of a non-resident (which is not a controlled foreign affiliate) that has been outstanding for more than a year. ... One is that this is simply a result of the negotiation – some countries (e.g., poorer countries) prefer a higher rate. ...

Instead of having to pay the whole amount of $400,000 as a taxable dividend so that it can be established that the Part IV tax of $153,333 is fully refunded for subsection 55(2) to apply, Holdco would only need to pay an amount of $160,000 as a taxable dividend ($61,333 / 38.33%). ... In the second return, the following will have to be reported: Taxable dividend received (before the application of s. 55(2) $400,000 Part IV tax paid $153,333 RDTOH Total of: Part I refundable tax on capital gain; $24,533 = $160,000 • 50% • 30.66% Total RDTOH $177,866 Dividend paid $160,000 Dividend refund Lesser of: RDTOH ($177,866) and 38.33% of $160,000 ($61,333) $61,333 Note that 2 returns, not more, are needed to be filed to reflect the application of 55(2) and that there is no circular calculation involved. ... Question 16: Medical Expenses – Medical Assistance in Dying The Supreme Court recently issued its ruling in Carter v. ...

Significantly Lacking in Economic Substance – The Three Factors The proposed test for lack of economic substance uses the “and” to join the three factors. ... Another central idea, where there is asset within the group – do you actually care where in the group that asset is held? ... So you are weighing certainty on the one hand for taxpayers versus the fairness of the tax system – which is what the GAAR does. ...

Question 1: Meaning of “Habitual Abode” in Canadian Tax Treaties As you know, Canada’s extensive treaty network contains residency “tie-breaker” provisions – usually in Article IV:2 of most of the treaties. ... Question 9: Subsection 247(4) – Contemporaneous Documentation and COVID-19 Canada’s contemporaneous documentation (“CD”) rules in subsection 247(4) require the completion of CD meeting statutory requirements within six months of the end of the relevant taxation year, a shorter time limit than is found in the analogous rules of most of Canada’s G7 contemporaries (typically one year). ... To request this type of relief, a taxpayer has to complete Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties and Interest. ...

Email this Content Joint Committee and other submissions 2025 2024 2023 2022 2020 2019 2018 2017 2016 2015 2014 2013 2012 2011 2010 2009 2008 2007 2006 Date Copy of submission re: Principal topics 2025 Apr 15 Suggested technical amendments to current ITA provisions Proposed technical amendments to EIFEL rules re s. 78(1)(a), s. 80(2)(b), s. 18.2(1) – excluded entity – (c), s. 18.2(1) – tax-indifferent, s. 18.2(1) – adjusted taxable income – C – (a), s. 18.2(1) – excluded lease, share buyback tax s. 183.3(1) – substantive debt – (c), s. 183.3(2), related company butterfly s. 55(5)(e)(i), Pt. ... Canada, 2020 FCA 21, s. 212(1)(i), s. 214(15)(b), s. 56.4(1)- restrictive covenant, consent, commitment and standby fees, early exchange bonus June 11 CRA Guidance re COVID-19 impact on international transactions COVID-19, designated treaty country, Reg. 5907(1)- exempt earnings, a. 95(1) – investment business, permanent establishment, non-qualifying country, services PE, qualifying non-resident employee June 1 19 May 2020 draft Time Limits and Other Periods Act (COVID-19) s. 180(1), s. 152(4), s. 152(3.1), s. 37(11), s. 127(9)- investment tax credit- – para. ... /FTC generators-FAT/interest on refunds May 3 2010 Budget: Non-Resident Trusts and FIEs non-resident trusts/foreign investment entities April 21 IT Bulletins re archiving all IT Bulletins Feb. 15 Dec. 18, 2009 Foreign Affiliate Amendments f.a. elections/s. 93(1)/fill the hold/bump/design. treaty country/FAPLs & FAT 2009 Sept. 30 Declaration Process re Treaty Witholding Rates Part XIII/Declaration of Benefits/waiver of penalties and interest April 1 Québec Paper on Aggressive Tax Planning GAAR penalties/promoter penalties/disclosure requirements Jan. 7 NRTs and FIEs non-resident trusts and foreign investment entities 2008 Sept. 15 July 14, 2008 SIFT Amendments "excluded subsidiary entity"/SIFT partnerships/SIFT trusts July 15 Canada's System of International Taxation foreign debt/treaty shopping/active business income/NRTs & FIEs/base erosion rules/FAPI June 18 SIFT Conversions SIFT trusts/asset transfers/continuity of tax attributes June 4 Bill C-10 NRTs/dual-resident trusts Senate Standing Committee comfort letters/residence/NRTs & FIEs/94(1)- "exempt foreign trust" Jan. 24 Bill C-10 NRTs & FIEs Jan. 8 Fifth Protocol treaties: residence/dividends/employment income/limitations on benefits 2007 Dec. 4 SIFT Conversion debt rollover/SIFT partnerships Oct. 23 2007 Budget 20(1)(e)/18.2(3)(a)(ii)- "substituted property"/18.2(9), (10)/s. 95.2(f), (f.1)/93.1 June 1 Foreign Affiliate Amendments accounting burden May 7 International Fair Tax Initiative grandfathering/uncertainty March 7 Bill C-33 – Ss. 52(3)(a), 53(1)(b) CDA/dividends/PUB increases/contributed surplus Feb. 21 "Normal Growth" for Income Trusts SIFT conversions/ambiguities in Guidelines Jan. 31 Dec 21, 2006 SIFT amendments deemed dividends/"investment"/"business"/"non-portfolio earnings" & "non-portfolio property"/REITs/"real or immovable property" 2006 Dec. 4 Eligible Dividend Rules 89(14) Sept. 29 Outstanding Income Tax Proposals interest deductions/foreign investments/foreign affiliates/interest & penalty relief Jan. 30 July 18, 2005 Technical Amendments attached submissions not in document Jan. 27 November 17, 2005 NWMM- S. 143.3 attached submissions not in document Jan. 20 Feb. 27 2004 Foreign Affiliate Amendments foreign affiliate PUC/foreign PUC currency/hedging arrangement currency ...