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8 December 2009 Roundtable, 2009-0347711C6- Subsection 116(5.02) Notice & Estimates Unedited CRA Tags 116(5.01), 116(5.02) Principal Issues: Can a purchaser file a Notice under subsection 116(5.02) when the purchase price is estimated as of the date of the acquisition? ...

10 June 2011 Roundtable, 2011-0398371C6- HWTs and Employee Life & Health Trusts Unedited CRA Tags 144.1 Principal Issues: What is the CRA's current position with respect to revising IT-85R2? ...

7 November 2002 CTF Roundtable Q. 1, 2002-0144140- CTF STEWART & WALLS Unedited CRA Tags 9 Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA. ... Principal Issues: 2002 Canadian Tax Foundation Q & A regarding the Supreme Court of Canada decisions in Stewart and Walls. ...

28 May 2015 IFA Roundtable Q. 5, 2015-0581531C6- IFA 2015 Q.5: "Causality test" in 18(6) & 212(3.1) CRA Tags 18(6) 212(3.1) 17(2) Principal Issues: What is the requisite degree of linkage, between a debt owing by the taxpayer to a creditor and a secondary obligation existing between that creditor (or someone not dealing at arm's length with that creditor) and certain non-residents, sufficient to potentially engage subsection 18(6.1) and 212(3.2), respectively? ...

8 June 2007 Roundtable, 2007-0240431C6- 2007 STEP Conf-Q. 12-Change in Trustees & Cntrl Unedited CRA Tags 257(7)(a) 256(1) Principal Issues: Can the CRA advise if there have been any further developments on the issue of whether a change in any of the trustees of a trust would result in a change in control of the corporation of which the trust is the shareholder? ...

21 December 2006 Roundtable, 2006-0215491C6- timing recognition foreign currency gains & losses Unedited CRA Tags 39(2) Principal Issues: When to report a foreign currency gain or loss in respect of funds denominated in a foreign currency on deposit for the purposes of the Act Position: Depends on whether the gain or loss is on account of capital or on revenue account. ...

21 November 2017 CTF Roundtable Q. 11, 2017-0724081C6- ULC-LLC structures & Treaty Unedited CRA Tags Articles IV(1), IV(6), IV(7) and X(2) of the Canada-U.S. ...

5 December 2017 Roundtable, 2017-0723491C6- 2017 TEI – Question B6- 55(2) guidance Unedited CRA Tags 55(2) Principal Issues: Rulings issued under 55(2) Position: See document Reasons: See document 2017 TEI Conference Round Table Question B6: Subsection 55(2) guidance TEI members remain concerned about how revised subsection 55(2) and, in particular, the broad purpose test in subsection 55(2.1) will be administered. ...

16 May 2018 IFA Roundtable Q. 9, 2018-0748151C6- T1134s & Country by Country Reporting Principal Issues: Has the CRA surveyed its large file case managers to enquire whether or not T1134s are, in fact, used as a risk assessing tool in the context of companies of a size that are subject to CbC reporting? ...

10 December 1996 TEI Roundtable Q. 8, 9638920- OUTSTANDING CHEQUES & GROCERY PEOPLES CASE Unedited CRA Tags 181.2(3) 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. ...