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Does the requirement of s. 144.1(2)(f) (dating from before the introduction of the Alternative Condition) – that the rights under the trust of each key employee are not more advantageous than the rights of a class of beneficiaries described in s. 144.1(2)(e)- apply only where the Beneficiary Condition is relied upon (so that where the Alternative Condition is met, the plan is not required to satisfy s. 144.1(2)(f))? CRA responded: The condition in paragraph 144.1(2)(f) … should only apply where a trust meets the condition in subparagraph 144.1(2)(e)(i) … and does not apply to a trust that meets the condition in subparagraph 144.1(2)(e)(ii) … ...

. … [P]aragraph [146.1(6.1)(b)] could cause the years of existence of the transferring RESP to be taken into account in determining when "accumulated income payments" may be made under the receiving RESP pursuant to 146.1(2)(d.1). If applicable, those years would also be taken into account in determining the maximum duration of the receiving RESP provided in paragraph 146.1(2)(i) and determining the period during which contributions may be made into the receiving RESP pursuant to paragraph 146.1(2)(h). … However, depending on the circumstances, a transfer between RESPs could result in the subscriber of the transferring RESP, the receiving RESP, or both, having to pay tax under subsection 204.91(1) … [but not in] the situation described …. ...

…[A] gain of $150,000 … in respect of the disposition of … the policy should be included in computing his income for the taxation year of his death …. ...

Customized remittance vouchers for businesses can be obtained quickly and easily through the CRA Web site … or through the "My Business Account" service …. ...

7 October 2021 APFF Roundtable Q. 14, 2021-0901041C6 F- Meaning of Any consideration received by Donee-- summary under Paragraph 118.1(13)(c) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(13)- Paragraph 118.1(13)(c) “consideration … received” in s. 118.1(13)(c) includes a s. 84(3) deemed dividend Under s. 118.1(13)(c), where a qualified donee that disposes of non-qualifying securities (“NQS”) that were gifted to it, the amount of the original gift will be deemed in some circumstances to equal the fair market value of the “consideration” received by the donee for that subsequent disposition. ... CRA responded: [G]enerally speaking, and in the absence of any indication to the contrary … the notion of "consideration" is broad enough to encompass any amount, good or service received upon the disposition of property. The CRA is of the view that the word "consideration" in the phrase "fair market value of any consideration … received by the donee for the disposition … of the security" in paragraph 118.1(13)(c) must be given the broad meaning generally accepted in the jurisprudence. ...

18 June 2015 STEP Roundtable Q. 11, 2015-0578551C6- 2015 STEP–Q11-Subsection 118.1(5.1)-sub property-- summary under Subsection 118.1(5.1) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(5.1) share redemption proceeds – but not by a dividend – are substituted property Amended s. 118.1(5.1) require that a donation be a gift of "property that was acquired by the estate on and as a consequence of the death" or "property that was substituted for that property. ...

. … 2012-0456221R3 is therefore still valid … ...

There is no provision … that allows for a different calculation … in this situation. ...

CRA stated: The entity was to be created as a French SLP – which is a “Fonds Professionnel Spécialisé” – established as a “société en commandite simple” (“SECS”). ... CRA noted the following salient characteristics of an SLP established as a SECS [usually translated as "limited partnership"]: the existence of a separate legal personality that is recognized under the law of the relevant foreign jurisdiction – meaning the entity’s full legal capacity to acquire and own property, to sue and be sued, to carry on its own activities and to incur liabilities of its own; the limitation of liability afforded to all of its “limited members”; the unlimited liability of the “general member”; and the computation of earnings at the entity level, with a distribution mechanism akin to the declaration and payment of a dividend. ...

29 May 2018 STEP Roundtable Q. 9, 2018-0744111C6- Vested Indefeasibly-- summary under Paragraph (g) Summary Under Tax Topics- Income Tax Act- 101-110- Section 108- Subsection 108(1)- Trust- Paragraph (g) meaning of vested indefeasibly For purposes of the 21-year deemed disposition rule, a trust does not include a trust "all interests in which … have vested indefeasibly". ... CRA also referenced Boger Estate, which indicated that vesting occurs when there is no condition precedent to be fulfilled before the gift can take effect, and the persons that are entitled are ascertained and ready to take possession – there can be no prior interest in existence – and that a vested interest becomes indefeasible where there is no condition subsequent, or determinable limitation set out in the grant. ...