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1999 Ruling 9903543- TOTAL RETURN SWAPS & MUTUAL FUND TRUST-- summary under Subsection 18.1(15) Summary Under Tax Topics- Income Tax Act- Section 18.1- Subsection 18.1(15) An open-end unit trust invests the proceeds of a public offering in a note of a bank and then enters into a total-return swap with the Bank respecting a bond index (some of the components of which correspond to bonds held by the bank). ...

27 November 2018 CTF Roundtable Q. 13, 2018-0779991C6- 20(1)(c) & Triangular Amalgamation-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by parent for use in connection with a triangular amalgamation to redeem preferred shares issued by Target can be deductible In a triangular amalgamation, is the interest on a third party loan obtained by ParentCo to redeem preferred shares issued by TargetCo as part of the transaction deductible under s. 20(1)(c)? ...

15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6- 78(1)(b)(ii) deemed loan & thin capitalization-- summary under Subparagraph 78(1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 78- Subsection 78(1)- Paragraph 78(1)(b)- Subparagraph 78(1)(b)(ii) deemed s. 78(1)(b)(ii) loan is not also deemed to bear interest The thin cap rules apply to “outstanding debts to specified non-residents”, whose definition specifies that there is deductible interest paid or payable on them. ...

7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician-- summary under Income or Loss Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4)- Income or Loss royalty income was incident to composing active business Gagliese Productions found that a company which earned royalties from the daily activities of its sole shareholder and employee in writing and producing music for TV episodes was earning income from an active business rather than from a specified investment business. ...

2020 Ruling 2019-0799981R3- Disposition – Reclassification and Stock Split-- summary under Subsection 116(1) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(1) no s. 116 certificate required for simultaneous consolidation of multiple identical series into one series, and stock split With a view to going public, a closely-held US corporation, whose issued and outstanding shares (which were taxable Canadian property and held by Canadian and US-resident corporate shareholders) consisted of seven series of common shares with identical attributes, proposed to amend its articles of incorporation so as to reclassify all the common shares into one series and to simultaneously effect a stock split. ...

8 July 2020 CALU Roundtable Q. 2, 2020-0842141C6- Return of premiums on death & CDA-- summary under Paragraph (j) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(9)- Disposition- Paragraph (j) a refund of premiums on death under a life insurance policy does not entail its disposition A private corporation is the owner and beneficiary of an exempt life insurance policy (with an adjusted cost basis of $90,000) on the life of a shareholder, who dies from, say, suicide or skydiving, which does not void the policy, but instead results in the insurer repaying all premiums ($100,000). ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 4, 2020-0851621C6 F- RRSP or RRIF on death – Joint election-- summary under Subsection 146.3(6.1) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6.1) specific bequest of RRIF is treated as passing through the estate’s hands, so that a s. 146.3(6.1) election is necessary Where a RRIF is the subject of a specific bequest made to the deceased annuitant's spouse under a Quebec will and the RRIF proceeds are distributed by the RRIF issuer directly to the surviving spouse, CRA considers that the RRIF proceeds passed through the estate rather than coming directly out of the RRSP, as required under the “designated benefit” definition. ...

4 May 2021 External T.I. 2020-0853361E5 F- Frais d'asepsie / asepsis fees-- summary under Paragraph 118.2(2)(a) Summary Under Tax Topics- Income Tax Act- Section 118.2- Subsection 118.2(2)- Paragraph 118.2(2)(a) additional dentists’ charges for COVID precautions qualified Regarding fees paid to a dentist for additional “asepsis” provided during the oral examination and treatment of children's cavities during the COVID pandemic, i.e., for additional procedures that prevent COVID infection such as personal protective equipment (gloves, mask, protective glasses, lab coat, etc.), cleaning, disinfection and sterilization, CRA stated: [A]n individual's eligible medical expenses include fees paid to a dentist for dental services provided to the individual, the individual's spouse or common-law partner, or a dependant of the individual, in the taxation year in which the fees were incurred. ...

15 June 2022 STEP Roundtable Q. 13, 2022-0929381C6- 164(6) – Amending Deceased’s Final T1 Return-- summary under Paragraph 164(6)(e) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(6)- Paragraph 164(6)(e) s. 164(6) amendment must be made through filing an amended return, not a T1 Adjustment Request The conditions for allowing capital losses of a graduated rate estate in its first taxation year to be considered capital losses of the deceased pursuant to s. 164(6) include that an election is filed, and the legal representative amend the deceased’s final T1 return of income. ...

7 October 2022 APFF Roundtable Q. 3, 2022-0942121C6 F- THRP- PRTA – Versement de dividendes imposables-- summary under Subsection 125.7(14.1) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(14.1) there is no adverse CEWS impact of a non-resident parent paying dividends to individuals Regarding the presented proposition that publicly traded companies or their subsidiaries are not entitled to any CEWS grants for the claim period in which dividends were paid to individuals who are holders of common shares, and the presented example of a parent company listed on the Paris stock exchange, with a Canadian subsidiary in Canada and an individual shareholder, which declares a dividend to be paid on March 31, 2022, CRA effectively indicated that the payment of a dividend at the parent level was irrelevant, and there would only be an adverse CEWS impact under the rules in ss. 125.7(2.01) and (14.1) if the Canadian subsidiary itself paid a dividend to an individual. ...