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Thus … Mr. X could be in a position to satisfy all the conditions set out in the definition of "qualifying withdrawal" insofar as, in particular, his qualifying home should be habitable from September 1, 2024 and he intends to begin using it as his principal place of residence on that date. ...

. … Consequently, the reduced rate of 15% provided for in Article XXII:2 of the Convention may be applied to amounts distributed from TFSAs and RDSPs to a U.S. resident where such TFSAs and RDSPs are constituted as trusts and are described in paragraph 212(1)(r.1) or 212(1)(p), as the case may be. ...

. … Words and Phrases credit ...

. … Words and Phrases credit ...

Consequently, we remain of the view that any determination of whether section 9, paragraph 12(1)(x), or subsections 15(1), 56(2) or 246(1) of the Act apply to a particular shared-ownership arrangement involving life insurance policies and their respective premium payments can only be ascertained, on a case-by-case basis …. ...

Accordingly, an amount received by Spouse B from the Preference Shares would not constitute an “excluded amount” to Spouse B under paragraph (b) …. ...

CRA indicated that such a deemed resident trust is not subject to Part XIII tax on amounts paid or credited to it, but is not considered to be resident in Canada for the purposes of determining the liability of a person other than the trust to withhold and remit under s. 215 – so that there is still a requirement to withhold and remit Part XIII tax on the rent paid to such trust. ...

4 June 2024 STEP Roundtable Q. 13, 2024-1007851C6- DRT and Section 216-- summary under Paragraph 94(3)(g) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(3)- Paragraph 94(3)(g) although resident tenant required to withhold on rent to s. 94(3), s. 94(3)(g) applies to such withholding Regarding the application of Part XIII to a non-resident trust that is deemed to be resident in Canada pursuant to s. 94 and which owns a Canadian rental property, CRA indicated that such trust is not subject to Part XIII tax on amounts paid or credited to it, but is not considered to be resident in Canada for the purposes of determining the liability of a person other than the trust to withhold and remit under s. 215 – so that there is still a requirement for the Canadian tenant(s) to withhold and remit Part XIII tax on the rent paid by them. ...

CRA has viewed a société en commandite simple in France as a partnership, irrespective of whether it has irrevocably elected to be taxed as a corporation in France – and similarly, the recent enactment of reverse hybrid rules in Luxembourg would not be determinative. ...

CRA has viewed a French société en commandite simple as a partnership, irrespective of whether it has irrevocably elected to be taxed as a corporation in France – and similarly, the recent enactment of reverse hybrid rules in Luxembourg would not be determinative. ...