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Conference summary
7 June 2019 STEP Roundtable Q. 2, 2019-0798491C6 - Alter ego trust and donations -- summary under Total Charitable Gifts
(b) Here, in contrast, the fact that the trustee may make payments over the three years suggests that the trustee may have discretion and the payments may be voluntary – so that the payments to the charity over the three years may be eligible for the donation tax credit. ...
Conference summary
7 June 2019 STEP Roundtable Q. 12, 2019-0798301C6 - Attribution under 75(2) -- summary under Subsection 204(1)
Reg. 204 imposes a requirement to file a T3 return where the trustee has control of, or receives, income, gains, or profits in the trustee’s fiduciary capacity – even if the Trust computes nil income. ...
Technical Interpretation - Internal summary
1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement -- summary under Subsection 32.1(1)
Given the potentially significant differences in both the amount and timing of the reimbursement payment as compared to the actual contributions made by Parentco … the reimbursement payments are not equivalent to Parentco’s contributions to the EBP, and thus cannot be considered to be a proxy for those contributions. ...
Technical Interpretation - Internal summary
1 August 2019 Internal T.I. 2018-0781951I7 - Employee benefit plan and recharge agreement -- summary under Subsection 152(4)
If it is determined that the TPRs were due to an error … the TPRs for all of the taxation years could be accepted. ...
Conference summary
3 December 2019 CTF Roundtable Q. 16, 2019-0824471C6 - Eligible Dividend Designation -- summary under Subsection 89(14)
After responding negatively, CRA stated:... 2009-0347491C6 … provided examples of acceptable notifications of the payment of an eligible dividend from a corporation other than a public corporation to the dividend recipient. ...
Conference summary
11 October 2019 APFF Roundtable Q. 3, 2019-0812621C6 F - Changement d’usage-impact sur l’exemption pour résidence principale -- summary under Paragraph (c)
The taxpayer will therefore have to file two worksheets and two T2091 forms … if the taxpayer wishes to designate Unit 2 and Unit 3 as his principal residence for the applicable years. ...
Conference summary
11 October 2019 APFF Roundtable Q. 10, 2019-0812691C6 - Consolidated safe income -- summary under Paragraph 55(2.1)(c)
Should the safe income attributable to the shares of Holdco be reduced by negative safe income given that the latter does not reduce the accrued capital gain in the shares – or is such amount $900,000? ...
Technical Interpretation - External summary
9 April 2020 External T.I. 2014-0527261E5 F - Beneficial ownership discretionary power of trustees -- summary under Paragraph 107.4(1)(i)
Consequently, the requirement in paragraph 107.4(1)(i) would be satisfied …. ...
Technical Interpretation - External summary
12 June 2020 External T.I. 2018-0788161E5 F - Adjusted stub period accrual amount -- summary under Element B
Consequently … no limited partnership loss can be deducted by Opco in computing the ASPA so as to reduce the amount to be added to its income under subsection 34.2(1). ...
Conference summary
8 July 2020 CALU Roundtable Q. 5, 2020-0842191C6 - Jointly owned policies - 70(5.3) -- summary under Subsection 70(5.3)
. … The CRA does not have its own method for computing the FMV; this computation is based upon the facts known on the valuation date, to which the principles and standards of the Canadian Institute of Chartered Business Valuators are applied. ...