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15 June 2022 STEP Roundtable Q. 13, 2022-0929381C6- 164(6) – Amending Deceased’s Final T1 Return-- summary under Subsection 164(3) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(3) commencement of refund interest where loss transferred from GRE to terminal return If an election under s. 164(6) results in a refund, when does interest begin to accrue thereon? ...

7 October 2022 APFF Roundtable Q. 3, 2022-0942121C6 F- THRP- PRTA – Versement de dividendes imposables-- summary under Subsection 125.7(2.01) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(2.01) parent could pay a dividend in, say, Period 27, without adverse CEWS impact on Canadian sub Reference was made to the impact on the Tourism and Hospitality Recovery Program ("THRP") of the introduction of ss. 125.7(2.01) and 125.7(14.1) with effect for Periods 23 and beyond. ...

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 2, 2022-0936281C6 F- police d'assurance-vie & avantage-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) taxable benefit where 2 Holdcos pay premiums on life insurance policies of which their jointly-owned sub is beneficiary unless s. 246(2) applies Suppose that two brothers resident in Canada each have a Holdco owning 50% of Opco and that, in order to fund the buy-sell agreement on the death of an ultimate shareholder, each Holdco has purchased insurance on the life of its sole shareholder, with Opco as the revocable or irrevocable beneficiary of both insurance policies. ...

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 2, 2022-0936281C6 F- police d'assurance-vie & avantage-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement premiums paid by parent on a sub’s life insurance policies are non-deductible even if reimbursed on income account Two brothers resident in Canada each have a Holdco owning 50% of Opco. ...

12 September 2022 External T.I. 2021-0886441E5- Restricted Stock Unit Plan – Adjusted Cost Base-- summary under Subsection 7(1.31) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.31) example of application of s. 7(1.31) to acquisition and immediate sale of shares pursuant to RSUs An employee who acquired 10 common shares of the employer, a public corporation, on capital account, was also issued, for no consideration (other than services rendered), 10 restricted stock units (RSUs) of the employer under an agreement to which s. 7(1) applied. ...

12 September 2022 External T.I. 2021-0886441E5- Restricted Stock Unit Plan – Adjusted Cost Base-- summary under Subsection 47(3) Summary Under Tax Topics- Income Tax Act- Section 47- Subsection 47(3) application of ss. 7(1.31) and 47(3) to the acquisition and immediate sale of RSU shares S. 7(1.31) applies in relation to shares of a public corporation if a share of the corporation is acquired under an agreement described in s. 7(1), an identical share is disposed of within 30 days after that acquisition, no other identical shares are acquired or disposed of by the employee after that acquisition and before the disposition, and the employee makes the required designation. ...

17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit”-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion Art. ...

15 September 2020 IFA Roundtable Q. 6, 2020-0853561C6- Subsection 212.3(9) & The GAAR-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) circular transactions to effect a s. 212.3(9)(b)(ii) PUC reinstatement abused that provision Canco (wholly-owned by NRco) acquired all the shares of FA1 for $100, thereby effecting a reduction of the paid-up capital (PUC) of the common shares of Canco by $100. ...

5 May 2021 IFA Roundtable Q. 7, 2021-0887521C6- Section 247, FAPI & Subsection 80.4(2)-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) a non-interest-bearing loan from a CFA to a NR sister of the Canadian taxpayer would generate imputed interest and FAPI to CFA, plus s. 80.4(2) application to sister A wholly-owned foreign subsidiary (FS) of CanCo uses funds generated from its operations to make a non-interest bearing loan to a foreign borrower (FB), which is wholly owned by the foreign parent (FP) of CanCo. ...

5 May 2021 IFA Roundtable Q. 7, 2021-0887521C6- Section 247, FAPI & Subsection 80.4(2)-- summary under Subsection 80.4(2) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(2) a non-interest-bearing loan from a CFA to a NR sister of the Canadian taxpayer generated double tax (FAPI and Pt. ...