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The service standard for a Ruling is 90 business days commencing with the receipt of all information required from the client as outlined in Appendix A – Ruling Request Checklist of Information Circular IC 70-6R11, Advance Income Tax Rulings and Technical Interpretations (footnote 2) (IC 70-6). ... Remission of the service fee will be granted when the Ruling is issued, or the Pre-ruling Consultation is completed, subsequent to its service target date, as set out in Appendix H – Remissions of IC 70-6. ...

Yes; a description of the process and the required information is detailed in this response. 2022 CTF Annual CRA Round Table – November 29, 2022 Question 5: The New Proposed Critical Mineral Exploration Tax Credit Background In order for taxpayers to be eligible for the critical mineral exploration tax credit (“CMETC”) one of the requirements is that a qualified professional engineer or professional geoscientist provide certification within the 12-month period immediately preceding the time that the flow-through share (“FTS”) agreement is made, in prescribed form and manner, that the expense will be incurred pursuant to an exploration plan that primarily targets critical minerals. ... However, where proposed legislation results in an increase in benefits (for example, Canada child tax benefit) to the taxpayer, or if a significant rebate or refund is at stake, the CRA’s past practice has generally been to wait until the measure has been enacted. … Generally speaking, the CRA will not reassess if the initial assessment was correct in law. ...

Reasons: An exempt person defined in subsection 94(1) is excluded from the definition of resident beneficiary in subsection 94(1). 2023 STEP CRA Roundtable – June 20, 2023 Question 6: Non-Resident Trust and Canadian Charity A long-term Canadian resident becomes a non-resident and within 60 months, for reasons not related to Canadian tax, settles a non-resident trust for non-resident family members. ... Dawn Dannehl 2023-095957 FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 Pursuant to the definition in subsection 248(1) a “registered charity” must be resident in Canada. 2 The Act means the Income Tax Act R.S.C. 1985 (5th Supp.) c.1 as amended from time to time and consolidated to the date of this response and, unless otherwise expressly stated, every statutory reference herein is a reference to the relevant provision of the Act. 3 A trust to which paragraph 94(3)(a) applies is deemed to be resident in Canada only for the purposes listed in subparagraphs 94(3)(a)(i) to (x). 4 Resident contributor is defined in subsection 94(1) as, “ ‘resident contributor’ to a trust at any time, means a person that is, at that time, resident in Canada and a contributor to the trust...” ...

20 June 2023 STEP Roundtable Q. 12, 2023-0959591C6- Corporate Beneficiary and CDA Unedited CRA Tags 89(1) – definition of capital dividend account; 104(21) Principal Issues: 1. ... Reasons: The wording of the provisions in the definition of capital dividend account in subsection 89(1). 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 12. ...

In February 2024, the CRA published form T1521 – Election for a Pertinent Loan or Indebtedness (PLOI) under Subsection 15(2.11). In April 2024, the CRA also published form T2311 – Election for a Pertinent Loan or Indebtedness (PLOI) under Subsection 212.3(11). ...

17 July 2008 IFA Roundtable, 2008-0272361C6- Limitation of Benefits Unedited CRA Tags Art XXIX A 2(d) & (e) Principal Issues: For purposes of applying the Limitation of Benefits Provision of the Canada-US Income Tax Convention, as amended by the Fifth Protocol (the "Canada-US Treaty"), will Canada look through limited liability companies ("LLCs") and other entities that are fiscally transparent for US purposes, in applying paragraphs 2(d) and (e) of the definition of "qualifying person" of Article XXIX A? ...

Reasons: 96(1), 103 and 245(2). 2014 CTF Annual Tax Conference Canadian Tax Foundation November 30 – December 2, 2014 CRA Round Table Q.5 Streaming Partnership Income Question Does the CRA accept the streaming of certain types of income (e.g., interest income) to a particular partner of a partnership where the partnership agreement provides for such allocation? ...

Reasons: See below. 2014 CTF Conference – CRA Roundtable Q.9- 95(6)(b) Post Lehigh How will the Federal Court of Appeal decision in Lehigh Cement affect the CRA's interpretation of paragraph 95(6)(b)? ...

CTF 2010 – November 28, 2010 Reasonable Salary for Incorporated Professionals Question 21 Paragraph 1(j) of Interpretation Bulletin IT-189R2 and paragraph 17 of Information Circular 88-2 are contradictory with respect to whether a reasonable salary should be paid to an incorporated professional. ...

Reasons: Previous positions and jurisprudence. 2012 Canadian Tax Foundation Annual Conference – CRA Panel November 2012 Recent files of interest Employee "Buyco" Rulings In the late 1990s and early 2000s, advance income tax rulings were issued on transactions which were designed to allow departing employee/shareholders of private corporations to realize a capital gain, as opposed to a deemed dividend, on the disposition of their shares. ...