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29 April 2015 External T.I. 2014-0532691E5 F- Vente – immeuble- syndicat copropriétaire-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation community of condominium owners is treated by the Civil Code as a legal person, and is a corporation A syndicate of co-owners holding condominium units sold one of the condominiums at a capital gain and distributed the gain to its members. ...

11 October 2013 Roundtable, 2013-0499671C6 F- Actif d'impôts futurs / Future income tax assets-- summary under Subparagraph (c)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (c)- Subparagraph (c)(i) future income tax asset is not an asset/tax receivable can be used in an active business Is a future income tax asset an asset used in an active business for the purposes of the definition of QSBC definition? ...

7 August 2015 Internal T.I. 2015-0585011I7- Osteopaths & naturopaths in Quebec-- summary under Subsection 118.4(2) Summary Under Tax Topics- Income Tax Act- Section 118.4- Subsection 118.4(2) Quebec osteopaths and naturopaths excluded in contrast to their eligibility for Quebec purposes Are osteopaths and naturopaths are authorized medical practitioners in the province of Quebec for purposes of the federal medical expense tax credit (METC)? ...

9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 3, 2015-0588951C6 F- Deductibility of interest – ss. 20.1(1)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) no source disappearance where interest-free advance to sub is forgiven The sole shareholder of a CCPC uses borrowed funds to make an interest-free advance to the CCPC, and the CCPC then makes a proposal under the BIA, which is accepted by the creditors and entails the shareholder advance being cancelled. ...

9 October 2015 APFF Roundtable Q. 20, 2015-0595681C6 F- Avantages imposables / dépenses d’entreprise-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) employer-provided parties, bike stands and internal recreation areas generally not taxable benefits It is "the CRA’s position is that when an employer offers free-of-charge, to all employees, a party or other social event, there is no taxable benefit if the cost per party or other social event does not exceed $100 per person. ...

16 November 2015 External T.I. 2014-0529361E5- Spousal trust & life insurance-- summary under Paragraph 73(1.01)(c) Summary Under Tax Topics- Income Tax Act- Section 73- Subsection 73(1.01)- Paragraph 73(1.01)(c) funding of life insurance policy is a benefit where proceeds to be paid to non-spouse In finding that the use of income or capital from a purported spousal trust to pay life insurance premiums on spouse's life would disqualify trust from inception, CRA stated: [T]he relevant legislation does not contain a requirement that the spouse “benefit” from the trust while alive.... ...

2 October 2015 External T.I. 2012-0463801E5 F- Déduction pour gain en capital – permis de pêche-- summary under Paragraph 110.6(1.3)(b) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(b) para. ...

6 May 2016 External T.I. 2016-0646411E5- Professional corporation & small business deduction-- summary under Specified partnership income Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified partnership income rulings for the multiplication of the small business deduction by professionals’ service corps will cease to apply CRA noted that the 2016 Budget proposes to extend the specified partnership income rules to partnership structures in which a Canadian-controlled private corporation (“CCPC”) provides (directly or indirectly, in any manner whatever) services or property to a partnership during a taxation year of the CCPC where, at any time during the year, the CCPC or a shareholder of the CCPC is a member of the partnership or does not deal at arm’s length with a member of the partnership (and that the Budget rules extend to comparable private corporation structures). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) drop-down of FA shares to non-share FA deemed to be for share consideration S. 95(2)(c) which, insofar as relevant to the question of how it dovetails with s. 93.2, is essentially identical to s. 85.1(3). ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election-- summary under Subsection 104(14) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(14) preferred beneficiary election and qualified disability trust election potentially can coexist Each of four grandparents of a disabled grandchild establishes a trust for the grandchild individual under their will, with one of the trusts being intended to be a qualified disability trust (“QDT”). ...