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16 June 2014 STEP Roundtable, 2014-0522971C6- STEP CRA Roundtable – June 2014- Question 3 CRA Tags 93.3 Principal Issues: How are equity interests in foreign corporations without share capital divided into deemed classes of capital stock? ... Reasons: Text of proposed 93.3 STEP CRA Roundtable – June 2014 QUESTION 3. ...

16 January 2017 Internal T.I. 2016-0651411I7- Reassessment period – transfer pricing Unedited CRA Tags ITA: 152(4)(b)(iii); 152(4.01)(b)(iii); 247(2); 124(4); ITR: 402(3) Principal Issues: Whether subparagraph 152(4)(b)(iii) of the Act allows the Minister to issue an assessment, reassessment or additional assessment of tax under Part I beyond the normal reassessment period (i) to reattribute taxable income earned in a province with respect to a sale of goods to a non-arm’s length non-resident person, (ii) to increase gross revenue attributable to a province that results from a transfer pricing adjustment. ... Ouimet, CPA, CA Attention: John Parker and Dan O’Neil 2016-065141 Reassessment period – transfer pricing We are writing in reply to your request of June 6, 2016, regarding the extended reassessment period under subparagraph 152(4)(b)(iii) of the Income Tax Act (the “Act”). ...

11 October 2017 External T.I. 2016-0660421E5- Foreign tax credit – former resident Unedited CRA Tags 126(2.21), 152(4)(b) and (c), 152(4.01), 152(6)(f.1) Principal Issues: Does subparagraph 152(4)(a)(ii) of the Act allow a taxpayer to file a waiver for an emigration year for the purpose of keeping the taxation year open indefinitely to allow the taxpayer to claim a foreign tax credit under subsection 126(2.21) beyond the statutory limits imposed under paragraph 152(4)(b)? ... Agarwal, CPA, CMA, MBA October 11, 2017 Dear XXXXXXXXXX: Re: Foreign tax credit – former resident This letter is in response to your emails dated July 4, 2016 and August 4, 2016, in which you seek clarification regarding the period within which the Minister may assess or reassess a taxpayer’s return of income with respect to a claim for a foreign tax credit under subsection 126(2.21) of the Income Tax Act (“Act”). ...

26 November 2020 STEP Roundtable Q. 13, 2020-0847201C6- GRE & section 216 election Unedited CRA Tags 248(1) graduated rate estate; 216; 107(2), 107(5), 117(2). 3(1) and 33(2) of the Interpretation Act Principal Issues: 1. ... Once the beneficiaries each hold beneficial ownership of their interest in the rental property, they could meet the conditions in section 216. 2020 STEP CRA ROUNDTABLE – November 26, 2020 QUESTION 13. ...

3 December 2024 CTF Roundtable Q. 11, 2024-1038241C6- Global Minimum Tax Act – Interpretation and Application of OECD Agreed Administrative Guidance Unedited CRA Tags GMTA 3(1); 17(6); 24 Principal Issues: In the case of a reverse hybrid that is fiscally transparent in relation to an indirect owner (an FT-CE), will the CRA administer the application of the GMTA based on the June 2024 Administrative Guidance? ... This includes the application of subsection 3(1), which is described in the Department of Finance’s Explanatory notes as intending “to ensure that the Act is interpreted, applied and administered in a manner consistent with the outcomes provided under the Model Rules, Commentary and Administrative Guidance (referred to in this note, collectively, as the “Pillar Two Rules”), including any future revisions or additions to the Pillar Two Rules”. 2024 CTF Annual Tax Conference CRA Roundtable Question 11- Global Minimum Tax Act – Interpretation and Application of OECD Agreed Administrative Guidance We understand that CRA Rulings has formed a new Specialty Tax Division, in the Income Tax Rulings Directorate (the “ITRD”) of the Legislative Policy and Regulatory Affairs Branch, and that, amongst other items, this new division is responsible for interpreting the new Global Minimum Tax Act (the “GMTA”), implementing Pillar Two in Canada. ...

7 February 1994 CTF Roundtable Q. 1, 4M09660- 1993 CTF QUESTIONS & ANSWERS Unedited CRA Tags 70(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... The grossed-up total of withholding tax is calculated by applying the following formula: Required payment = tax rate X interest payment 100 minus tax rate For example, the required payment of withholding tax on an interest payment of $1,000, assuming a withholding rate of 15%, would be calculated as follows: 15 X $1,000 = $176.47 (100- 15) Canada-U.S. ... Business & Property Income- Paragraph 18(1)(l) Question 60 What is the Department's current assessing practice in situations similar to Sie Mac Pipeline Contractors Ltd. (93 DTC 5158)? ...

A taxpayer who contracts with another person in order that this person performs SR & ED on his behalf and who pursues no activities, other than (1) retaining the rights pertaining to any results from the SR & ED performed and (2) commercializing these rights or results, cannot be said to derive substantially all of his revenue from the prosecution of SR & ED carried out by him, within the meaning of paragraph 2902(a) of the Regulations. ... It is our view that revenue arising from the prosecution of SR & ED generally envisages the provision of scientific research for a fee or a sale of the know-how developed, i.e. the rights. Whether paragraph 37(7)(e) of the Act would apply in a particular case would depend on whether or not the taxpayer can be said to derive all or substantially all of his revenue from the prosecution of SR & ED. ...

1993 External T.I. 9310110 F- CALU Ques. 13- Buy-Sell Agreement & Valuation of Shares Unedited CRA Tags 110.6(15)(b), 69 THE CONFERENCE FOR ADVANCED LIFE UNDERWRITING 1993 Annual Conference Question 13 As part of a buy-sell agreement among shareholders a corporation is the owner and beneficiary of life insurance policies on the lives of shareholders. ... Response (a)     The Department has not considered specifically whether such a dividend would reduce the fair market value of the shares, however, if the disposition of shares by the estate is governed by a bona fide buy-sell agreement among shareholders, its provisions should be determinative of value as stated in paragraphs 28 to 31 of Information Circular 89-3. ... (b)     Paragraph 110.6(15)(b) limits the fair market value of the insurance proceeds for the purposes of the definitions listed in the preamble to subsection 110.6(15). ...

23 February 1989 Income Tax Severed Letter 5-7409-   R. Albert (613) 957-2098 FEB 23 1989 Dear Sirs: Re: Scientific Research and Experimental Development ("SR & ED") Non-Government Assistance and Contract Payments We are responding to your November 30, 1988 request for an interpretation as to whether service fees payable by a foreign affiliate to a Canadian taxpayer would be considered as non-government assistance or a contract payment which would reduce the qualified expenditures made for purposes of calculating the investment tax credit ("I.T.C. ... The fee is determined by NRCo's share of the SR & ED expenditures incurred by Canco based on the ratio of NRCo's sales to worldwide related group sales, as in a typical cost-sharing arrangement. c) Canco retains all Canadians rights. NRCo has the exclusive right to use the results of the SR & ED worldwide, with the exception of Canada, at no additional charge. d) NRCo does not carry on business in Canada. ...

/ Does a monthly payment of a fixed amount paid to employees using their personal cell phone in the performance of the duties of their employment represent a reimbursement or an allowance? Position Adoptée: Il s'agit d'une allocation. / The amount would be an allowance. ... Par conséquent, il ne peut pas s'agir d'un remboursement de dépenses. / The fact that the contract with the service provider must be given to the employer is not a proof of payment. ...