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3 March 2015 External T.I. 2014-0540051E5 F- Indiens – Intérêts d'une institution hors réserve-- summary under Section 87 Summary Under Tax Topics- Other Legislation/Constitution- Federal- Indian Act- Section 87 life annuity purchased off reserve did not qualify An Indian with a redacted connection to a reserve purchased a life annuity for a financial institution off reserve given that there was no financial institution on a reserve within 100 km of him. ...

26 November 2013 Annual CTF Roundtable, 2013-0509061C6- Part XIII Tax & Standard Convertible Debentures-- summary under Paragraph 214(8)(c) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(8)- Paragraph 214(8)(c) interest and premium on standard convertible debenture not participating CRA is not inclined at this time to take the position that standard convertible debentures would in general constitute "excluded debt obligations" pursuant to paragraph 214(8)(c) of the ITA. ...

5 July 2015 External T.I. 2015-0588201E5 F- Apportez vos appareils personnels / BYOD-- summary under Paragraph 6(1)(b) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(b) fixed BYOD allowance not verified against receipts is taxable allowance CRA confirmed its view in 2014-0552731E5 that employees, who were required to use cell phones in the performance of their duties, received a taxable allowance when their employer paid them a fixed monthly amount (calibrated to each employee's duties) not in excess of their costs, given that the employer “did not require detailed receipts.” ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election-- summary under qualified disability trust Summary Under Tax Topics- Income Tax Act- Section 122- Subsection 122(3)- qualified disability trust preferred beneficiary and QDT elections not mutually exclusive Where, for example, four grandparents each established a trust for their mutual disabled grandchild under their wills, with one of the trusts (after death) now being intended to be a qualified disability trust, CRA confirmed that the designation of that trust as a QDT would not restrict the availability of the preferred beneficiary election for the other three trusts (and the fourth trust could make the preferred beneficiary election even if it had elected to be a QDT). ...

LLPs & LLLPs Classification-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation perhaps potential flexibility in applying the transition of LLPs from partnerships to corporations CRA largely repeated its position immediately below in 2016 IFA Roundtable, Q. 1 (as well as indicating that Anson has not changed its views on LLCs). ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Subsection 93.2(2) Summary Under Tax Topics- Income Tax Act- Section 93.2- Subsection 93.2(2) membership interest in Dutch cooperative ruled to be shares Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Dutch cooperative (DC), in consideration for a credit to the membership accounts of the contributing foreign affiliates equal to the FMV of the contribution, was eligible for s. 95(2)(c) rollover treatment, CRA ruled that DC was a corporation for the purposes of the Act, and a non-resident corporation without share capital for purposes of s. 93.2 and that membership interests in DC will be deemed to be shares of a single class by s. 93.2(2). ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 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) joint contribution of shares of FA to Netherlands co-op in consideration for credits to their respective membership accounts deemed to be for share consideration Ruling respecting the combined operation of s. 95(2)(c) (similar in this regard to s. 85.1(3)) and s. 93.2) on a joint contribution by the three foreign affiliate shareholders of a foreign affiliate of their respective shareholdings to a Dutch co-operative (with membership interests rather than share capital) in consideration for credits to their respective membership interest accounts. ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate-- summary under Subsection 90(6) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(6) inclusion not dependent of maintenance of creditor affiliate status Where a non-resident subsidiary (FA) of Canco has made a loan to a non-resident subsidiary (SisterCo) of Canco’s non-resident parent (Foreign Parent), CRA considers that it is irrelevant that FA has ceased to be a creditor affiliate of SisterCo two years later, as a result of the sale by Canco of FA to Foreign Parent, so that s. 90(6) could still apply to include the loan’s amount in Canco’ income. ...

7 October 2016 APFF Roundtable Q. 9, 2016-0652921C6 F- Résidence- actif utilisé / Residence- asset used-- summary under Share of the Capital Stock of a Family Farm or Fishing Corporation Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Share of the Capital Stock of a Family Farm or Fishing Corporation primary employee use qualifies farm house CRA will accept that a farm house is an active business asset for purposes of the definitions of “qualified small business corporation share,” “share of the capital stock of a family farm or fishing corporation” and "interest in a family farm or fishing partnership" if it is used more than 50% by farming employees who are providing their services in that capacity rather than as shareholder (or partner). ...

22 December 2016 External T.I. 2015-0608201E5 F- Capital distribution from trust & NR4-- summary under Subsection 212(11) Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(11) capital distributions other than of capital dividends not subject to Part XIII tax Although s. 212(11) deems all trust capital distributions to a non-resident beneficiary to be income distributions for Part XIII purposes, s. 212(1)(c) only imposes Part XIII tax on s. 104(13) income and capital dividend distributions. ...