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7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business royalty income from a music composing business is active business income Gagliese Productions found that royalty income of an author/musician was income from services because the person who derived the income was earning the income in the normal course of his business. ...

10 October 2024 APFF Roundtable Q. 2, 2024-1028371C6- Transfert intergénérationnel d’entreprise – nouvelles règles-- summary under Paragraph 84.1(2.32)(a) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(a) s. 84.1(2)(e) exception is available only for the 1st disposition if the subject corporation shares are sold in tranches A parent wishes to access the s. 84.1(2.31) or (2.32) rules regarding a transfer of the shares of Parent Inc. ...

10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 5, 2024-1023291C6 F- Paiements rétroactifs- Droits ou biens / Retroact-- summary under Subsection 70(2) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(2) s. 70(2) return can be filed before the filing deadline with an estimated amount if precise amount is not yet known due to administrative delay A taxpayer died in October 2021 after a pay equity settlement was reached with the Quebec government in June 2021. ...

. … … 2019-0799901C6 … and … Example 9 of … Guidance on the Application of the Split Income Rules for Adults provide useful general guidance …. In particular … 2019-0799901C6 … indicated that a husband and wife could both be considered to be actively engaged in the activities of a particular business carried on by their corporation on a regular, continuous and substantial basis for a particular year where the particular business did not require any other workers and only required them to spend on average 5 hours each per week in that business. ...

29 August 2023 CPAC Roundtable Q. 8, 2023-0983051C6- Automobile Expenses-- summary under Paragraph 8(1)(h.1) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) Gardner (re deducting a sales person’s expenses of occasional travel between her home office and her employer) will be followed only on similar facts Regarding the deductibility of automobile expense incurred by an employee, with a fully remote work arrangement, in connection with an occasional visit to the office from the home office, CRA stated: [T]raveling between an employee’s home, including a home office, and a regular place of employment (RPE) is generally considered personal travel …. … In this case, “regular” means there is some degree of frequency or repetition in the employee’s reporting to that particular location in a given pay period, month, or year. … For example, a work location may be considered to be a RPE of an employee even though the employee may only report to work at that particular location on a periodic basis (e.g., once or twice a month) during the year. Depending on the circumstances, an employee may have more than one RPE. … … [Although] Gardner … held that motor vehicle expenses related to an employee’s travel between their home office and the employer’s principal place of business were deductible employment expenses under paragraph 8(1)(h.1) … the CRA’s general position on travel between an employee’s home or home office and a location that is a RPE for that employee remains unchanged. ...

11 May 2005 Roundtable, 2005-0127081C6 F- États financiers- Impôt de la Partie I.3-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) GAAP refers to Canadian GAAP Where a Canadian public corporation prepares its financial statements in accordance with US GAAP, will this be accepted as GAAP under s. 181(3)(b): CRA responded: GAAP refers to the current accounting standards or principles established by the … CICA …. … Where the balance sheet is prepared in accordance with U.S. ...

7 October 2020 APFF Roundtable Q. 6, 2020-0852181C6 F- Par. 5(2)(b) of the Employment Insurance Act-- summary under Paragraph 5(2)(b) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Employment Insurance Act- Section 5- Subsection 5(2)- Paragraph 5(2)(b) CRA now applies a “proportionate attribution approach” in applying the s. 5(2)(b) test of “control … of … voting shares” Équipements Boifor, 2019 CAF 69 concluded that two shareholders did not have insurable employment by virtue of s. 5(2)(b) of the EIA given that they controlled more than 40% of Boifor's shares, taking into account those individuals’ shares held indirectly through a holding corporation, even though the shares were held on a 50-50 basis and no one individually held control of the holding corporation. ... CRA responded: In light of the FCA's decision, the CRA must now consider the proportionate attribution approach in similar situations to determine whether the employment of a person who controls more than 40% of the voting shares of the employing corporation is insurable. … … The proportionate attribution approach leads to the conclusion that the two shareholders each control more than 40% of Opco's voting shares (50% of 100%) for the purposes of EIA paragraph 5(2)(b). … The approach remains the same where the shareholders held 51% and 49% of the voting shares of Holdco, respectively. ...

In addition, the CRA generally considers that the Purpose Tests [in ss. 55(2.1)(b)(i) and (ii)] could apply to a dividend paid by an operating company to its corporate shareholder in order to dispose of surplus assets for the purpose of the purification and subsequent sale of [its] shares … 2017-0724021C6 …. … [T]he payment of the Dividend and the Sale are part of the same series …. ... Consequently, subsection 55(2) should likely apply …. ...

Subject to certain exceptions under subsection 4(3) … subsection 4(2) … specifically denies the deduction of items in sections 60 to 64 … in determining income from a particular source. Consequently, a deduction allowed under paragraph 60(s) … is not tied to a particular source …. The amount determined under paragraph 3(c) … which forms variable F of the “non-capital loss” definition in subsection 111(8) … will never be negative, and therefore deductions described in Subdivision E of the Act cannot create or increase the amount of a non-capital loss. ...

CRA responded: In … IT-99R5 … the CRA confirms that legal costs incurred to enforce pre-existing rights to interim or permanent support amounts are deductible. ... As a result of … Gallien v. The Queen … 2000 DTC 2514 … legal costs incurred to obtain spousal support pursuant to the Divorce Act, or under provincial legislation in the case of a separation agreement, are also deductible. However, in the case of common-law spouses, the legal costs incurred to negotiate either a … cohabitation contract or a separation agreement are for the establishment and negotiation of an entitlement to support. ...