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Official response 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 5, 2017-0707801C6 F- RRIF transfers – partition of family patrimony Q.6 Treatment of RRIF balance where survivor spouse dies before transfer On the death of Mr. ... The total charitable gifts are based on the "eligible amount … of a gift". ... Official response 6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 16, 2017-0705181C6 F- Hedging & George Weston Limited ...

In Situations 1 and 2, were the survivor payments and "exempt contributions," as defined in s. 207.01(1) (the "Definition") $90,000 and $100,000, respectively – and what about Situations 3 and 4? ... Official Response 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 8, 2019-0811901C6 F- RRIF – Minimum amount after death Q.9 Whether deemed payment under RRIF is pension income Is a “payment received” from a RRIF considered to be a “payment out of or under” a RRIF for purposes of the definition of “pension income” in s. 118(7). ...

Porter & Son Ltd. v. Minister of Finance (Nova Scotia) [1979] 5802 ETC (NSSC): owner of a crane provided by it with operator was the person using the crane; and Cairns Construction [1960] S.C.R. 619: builder was the person using building materials in the course of completing real property contracts)? ... The example cited from GST/HST Memorandum 19.2.3, Residential Real Property — Deemed Supplies, reflects the CRA’s current position on the interpretation of subparagraph 7(a)(i) of Part I of Schedule V to the ETA. ... Therefore, if legal ownership is not transferred to the particular individual with whom the builder entered into the agreement of purchase and sale – which seems to be the case in the situation described, as ownership of the new house seems to be transferred to the corporation as bare trustee – then the requirement in paragraph 254(2)(e) of the ETA is not satisfied and the Minister cannot pay a new housing rebate under subsection 254(2). ...

Similarly, the definition of "principal residence" in section 54 states that it is a residence “owned, whether jointly with another person or otherwise, … by the taxpayer”. ...

GAAR Consultation He noted that the August 9 GAAR consultation paper stated at its outset that Finance thinks the GAAR is working reasonably well – but, even so, it could do with a tune-up after more than 30 years of practice, experience, tax administration and case law. ... Although the paper sought to cover the possible proposals in a balanced manner, even being transparent where a possibility was perhaps not workable or necessary, some of the proposals still prompted strong reactions – all of which is an expected and useful part of the consultation process. ... Although the judicially developed analytical framework is reasonably sound, there are some cases that may benefit from a further statutory “nudge” with regard to economic substance – and the case was made for this benefiting the efficiency of the system overall. ...

Its structure differs in some respects from the rest of the MLI – it is a single cohesive arbitration provision and it does not have compatibility clauses with respect to each article. ... We learned quickly, when discussing that among European and other colleagues, that that does not mean much to them – they are not very familiar with salary arbitration in North America. ... Independent opinion is based on a precedent from the EU Arbitration Convention, and it would effectively work more like a court proceeding – with evidence rules and oral hearings. ...

We are also plugged into Dunn & Bradstreet data, and have an iteration of Watson as an appliance running in the background. ... How do transfer pricing audits work – how do they work in Canada, and how do they work internationally? ... The program cannot work without that – it is something we lost, and we need to put it back in the system. ...

Filings to amend the tax position of the trust and the beneficiary are as follows: • The trust would file Form T3A "Request for a Loss Carryback by a Trust" in connection with the loss year to request the loss be carried back to the prior year. • The trust would file Form T3-ADJ "T3 Adjustment Request" for the prior year to reflect a late subsection 104(13.1) or (13.2) designation so as to amend the trust's T3 Return. • The trust would issue amended T3 slips to the beneficiary for that prior year, reducing the income allocated. • The beneficiaries would file a Form T1-ADJ "T1 Adjustment Request" to reflect the revised T3 slip and to amend the T1 Return. ... Further, the settlor /grantor can exercise his / her power to revoke the trust at any time. The settled property often includes all personal, tangible, intangible and real property of the settlor / grantor. ...

If the individual had more adult children, the benefits of sprinkling would increase – and if there were no adult child, the benefits would be reduced. ... As we know, the reasonableness concept is not new to the Income Tax Act – which is not to say, of course, that there are not challenges in applying this approach in the context of dividends. ... We feel this is less of a misunderstanding than an apples-and-oranges comparison – since the analysis leads to a 73% tax-rate, the focus is strictly on the nominal amount of investment income. ...

On ratification, which will occur after all domestic procedures have been completed, countries will have to deposit their final reservations and notifications – so things can change between signature and ratification without any implications. ... A country can remove reservations – and generally that would mean adding or taking on more provisions from the MLI, but they cannot add reservations. ... The pertinent wording is: … at any time at or after the time … an obligation to pay or credit an amount as … a dividend on the shares, either immediately or in the future and either absolutely or contingently …. ...