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6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 5, 2017-0707801C6 F- RRIF transfers – partition of family patrimony-- summary under Paragraph 60(l) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(l) transfer from deceased's RRIF to RRIF of surviving spouse in settlement of claim A couple separated without proceeding to an official division of their assets. ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Clause 95(2)(b)(i)(A) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(b)- Subparagraph 95(2)(b)(i)- Clause 95(2)(b)(i)(A) provision of services for fee by CFA to Canco on arm’s length terms did not oust s. 95(2)(b)(i)(A) Four U.S. ...

29 May 2018 STEP Roundtable Q. 6, 2018-0743971C6- Excluded Shares – Holding Company-- summary under Excluded Shares Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares holding company shares do not qualify as excluded shares In general terms, is it possible for shares of a holding company to qualify as "excluded shares"? ...

2018 Ruling 2017-0711071R3- Use of subsidiary losses & ITCs after wind-up-- summary under Paragraph 88(1)(e.3) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(e.3) purchaser could acquire Lossco’s business through a sub LP and then acquire Lossco, accessing s. 88(1)(e.3) A foreign-owned Canadian-resident corporation (“Taxpayer”) used a subsidiary LP to acquire the sole business of a “Lossco” that was in CCAA proceedings and then, a number of years later (and perhaps well after the completion of the CCAA restructuring) it purchases the shares of Lossco for nominal consideration and winds up Lossco. ...

5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F- entreprise exploitée activement – revenu de location-- summary under Active Business Carried On by a Corporation Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Active Business Carried On by a Corporation question of fact whether a CCPC with too many employees to have a specified investment business carries on a business Realtyco is a CCPC holding in Canada six buildings each containing 50 residential units, which it rents out. ...

10 June 2003 External T.I. 2003-0018915 F- Attribution- Transfers & Loans to Corp.-- summary under Subsection 74.5(6) Summary Under Tax Topics- Income Tax Act- Section 74.5- Subsection 74.5(6) s. 74.5(6) applied to an estate-freeze exchange by individual’s Holdco of Opco common shares for preferred shares so that family trust could subscribe for Opco common shares An individual transferred all the common shares of Cco (which, at no point, was a small business corporation) in a s. 85(1) rollover to a Newco (Bco) in consideration for common shares of Bco (being all its common shares). ...

1 February 2005 External T.I. 2004-0083921E5 F- Société mandataire, gain & CIÉ-- summary under Non-Business-Income Tax Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(7)- Non-Business-Income Tax US taxes paid by a corporation based on falsely representing that the related gain was its gain could generate a FTC to the Canadian shareholder for which it in fact was agent A corporation acquired a building in the US as agent for its individual shareholder pursuant to a nominee agreement. ...

& Disc. Div. Shares-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) payment of dividends on discretionary dividend shares with no liquidation entitlement would not result in a significant reduction Two brothers each holding half of the shares (being common shares) of Opco, formed respective Holdcos, which subscribed for one newly-created Class F share of Opco. ...

27 March 2018 Internal T.I. 2017-0691941I7 F- Investissement frauduleux – Fraudulent Investment-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date court order ab initio declaring loan void would eliminate interest income Individuals had “invested” in what turned out to be a Ponzi scheme under which for many years they reported annual income inclusions for interest which they were treated as having reinvested in the scheme. ...

15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6- 78(1)(b)(ii) deemed loan & thin capitalization-- summary under Subparagraph (a)(ii) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(5)- Outstanding Debts to Specified Non-Residents- Paragraph (a)- Subparagraph (a)(ii) unpaid simple interest that is deemed to be a loan by s. 78(1)(b)(ii) generally is not outstanding debts to specified non-residents Assuming compound interest does not accrue on unpaid simple interest owing by a Canadian corporation to a non-resident creditor for which an agreement under s. 78(1)(b)(ii) was made so as to deem the amount of that simple interest to be a loan, is that deemed loan considered to be included in “outstanding debts to specified non-residents” as defined in s. 18(5)? ...