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LLPs & LLLPs-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Delaware and Florida LLPs and LLLPs as corporations CRA indicated that it has finalized its view that Florida and Delaware limited liability partnerships and limited liability limited partnerships are corporations for ITA purposes in light inter alia of their separate legal personality and limited liability for all members (and noted that "we see little substantive difference between LLPs, LLLPs and LLCs governed by the laws of the states of Florida and Delaware. ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Subsection 93.2(3) Summary Under Tax Topics- Income Tax Act- Section 93.2- Subsection 93.2(3) s. 95(2)(c) rollover can apply on a dropdown of shares made to an LLC as a contribution of capital rather than for “share” consideration Canco owns all the shares of FA1, which owns all the shares of FA2 and all the member interests of FA3, which is a “non-resident corporation without share capital” as per s. 93.2(1). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Paragraph 95(2)(c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(c) dropdown of shares made to an LLC as a contribution of capital deemed by s. 93.2(3) to be for "share” consideration FA1 (wholly-owned by Canco) transfers all of the shares of FA2 to another non-resident subsidiary of FA1, viz., a non-share corporation (“FA3”), as a capital contribution, i.e., no new member interests are issued by FA3. ...

LLPs & LLLPs Classification-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 facts and circumstances test respecting transition of LLPs to corporation status At 2016 IFA Roundtable, Q. 1, CRA indicated it had finalized its view that Florida and Delaware limited liability partnerships and limited liability limited partnerships are corporations for ITA purposes, but indicated that it was prepared as an administrative matter to continue accepting that an existing LLP or LLLP (that had been formed from scratch rather than being converted from an LLC) is a partnership if it is clear that the members are carrying on business in common with a view to profit, all members and the LLP or LLLP having been treating it as a partnership for ITA purpose, and the LLP or LLLP converts to a “true” partnership before 2018. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Dutch cooperative whose articles limited member liability was a corp Before ruling that the contribution of shares of a Netherlands private limited liability company to a newly-formed Netherlands cooperative (Dutch Co-op, or "DC"), in consideration for a credit to the membership accounts of the contributing foreign affiliates, 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. ...

2016 Ruling 2015-0571441R3- Dutch Cooperative- 93.2 & 95(2)(c)-- summary under Controlled Foreign Affiliate Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Controlled Foreign Affiliate non-resident subsidiaries CFAs of bottom-tier Cdn partnership and FAs of Canadian corporate partners Forco 1 is held through three stacked Canadian partnerships (the bottom one, “CanGP 3”) by two taxable Canadian corporations (Canco 1D and Canco 1A) which, in turn, are indirect wholly-owned subsidiaries of a non-resident parent (“Parent”). ...

12 April 2016 External T.I. 2015-0595461E5- Australian Super Fund & T1135-- summary under Paragraph (e) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Cost Amount- Paragraph (e) cost amount of pension rights includes future amounts to which legal entitlement An Australian Superannuation Fund (or “Super Fund”) is a government-regulated trust that has been registered and approved by the Australian Government and is funded by contributions from employers and individuals over their working lives in order to provide retirement incomes. ...

12 April 2016 External T.I. 2015-0595461E5- Australian Super Fund & T1135-- summary under Subsection 162(7) Summary Under Tax Topics- Income Tax Act- Section 162- Subsection 162(7) no penalty for reasonably estimating an unknown amount, e.g., the “cost amount” of a pension interest An Australian Superannuation Fund (or “Super Fund”) is a government-regulated trust that has been registered and approved by the Australian Government and is funded by contributions from employers and individuals over their working lives in order to provide retirement incomes. ...

10 May 2012 External T.I. 2012-0440731E5 F- Employer-provided gifts & Awards-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) award of points that could be applied to 40 different services were of near-cash items and, thus, taxable A corporation rewards employees (e.g., for achieving numbers of years of service) by awarding them points that can be applied to purchase 40 different listed services related to work-life-family balance set out in a catalogue, e.g., day care services for school days and spring break; and nutritionist, dietitian, massage therapist, psychologist, financial advisor, and home chef services. ...

8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10-- summary under Subsection 207.6(2) Summary Under Tax Topics- Excise Tax Act- Section 207.6- Subsection 207.6(2) In response to a question as to the circumstances in which a life insurance policy can "reasonably be considered to be acquired to fund in whole or in part," CRA indicated that the factors it would consider would include: the identity of the employees whose lives are insured as compared to those to be provided benefits under the plan; the timing of the acquisition of the insurance and the setting up of the plan; the timing of the acquisition of the insurance and the setting up of the plan; reasons (other than the existence of the plan) for the employer's purchase of insurance. ...