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2016 Ruling 2015-0612931R3- Variation of trust indenture-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition creation of new MFT units to indirectly bear trailer fees Proposed creation of new class of units to fund trailer fees The Declaration of Trust of an open-ended non-SIFT mutual fund trust (the “Trust”) with a corporate trustee (the “Trustee”) and with only one class of units will be amended to create two classes of units, so that the existing units will be re-designated as Class F units and a new class of units (Class A units) will be created which will have the same attributes as the Class F units except that they will bear exclusively an additional management fee, payable by an indirect subsidiary real estate operating LP to its GP (“Operating GP” – controlled by Trustee), which will fund the cost of trailer fees payable to investment dealers who have sold Class A units, with this resulting in a reduction of the distributions paid on the Class A, but not on the Class F, units. ...

The result is the same whether the circular calculations begins with the $800,000 dividend paid by one of the corporations, or the other …. 4 th Situation This is identical to the 3 rd, except that, in 2004, ABCco paid a taxable dividend of $100,000 to its parent. ...

Rulings Re qualification of expenditures under CEE – (f) and non-application of s. 245(4), and that s. 66(12.71) will not apply to prevent Bco from renouncing CEE provided that it is carrying on business in Canada. ...

Rulings Including re qualification of expenditures under CEE – (f). ...

. … [Y]our mother did not ordinarily inhabit the residence during the years XXXXXXXXXX to XXXXXXXXXX. ...

Rulings Including that s. 107(2) will apply to the distribution from the Trust of the Real Property to the Beneficiary such that: pursuant to s. 107(2)(a) the Trust will be deemed to have disposed of the Real Property for its cost amount, the Beneficiary will be deemed under s. 107(2)(b) to have acquired it at the same amount and under s. 107(2)(c) to have disposed of part of its capital interest for that amount minus the eligible offset amount, being the amount of the assumed debt, and pursuant to ss. 107(1.1), 107(1)(a), and s. 108(1) – “cost amount”, the adjusted cost base of the part of the capital interest in the Trust to the Beneficiary, immediately before the disposition of such part of the capital interest, will be deemed to be the total of all amounts each of which is the cost amount to the Trust of the distributed properties. ...

Specific clauses in the trust deed providing that certain types of payments will constitute income to the trust are acceptable- the “fact that the trust deed provides that certain types of payments will constitute income does not, in and of itself, determine whether the conditions of subsection 104(18) … are satisfied, including the condition referred to in subsection 104(18)(c).” ...

After quoting the statement in Ludco that “courts should objectively determine the nature of the purpose, guided by both subjective and objective manifestations of purpose,” CRA indicated that Ludco followed the purpose test in Symes, and the Symes / Ludco test (consistently with many other decisions) constitutes the benchmark of purpose. ...

21 November 2017 CTF Roundtable Q. 6, 2017-0724071C6- Circular calculations Part IV tax-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) where Holdco receives a dividend subject to refundable Pt IV tax and to s. 55(2), two different dividends should be reported for Pt IV and s. 55(2) purposes Holdco receives a dividend of $400,000 that is subject to Part IV tax of $153,333 (38.33% of $400,000) equalling the connected payer’s dividend refund and, in turn, pays a dividend to its shareholders resulting in a refund of the Part IV tax – so that the dividend received by Holdco is subject to s. 55(2). ...

Now a further estate freeze is effected under which Initial Trust exchanges its shares for preferred shares under s. 51 and a newly-formed discretionary family trust (“New Trust” – also having grandchildren and family corporations as beneficiaries and with a different unrelated individual as the third trustee) subscribes for new non-voting common shares. ...