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8 June 2007 Roundtable, 2007-0233801C6- 2007 STEP Conf-Q.2-Use of SIN for child Principal Issues: In Technical Interpretation # 9812245 (dated June 22, 1998) the CRA indicated that the social insurance number (SIN) of a child (under age 18) is not required if the child's income is expected to be $2500 or less. ... Reasons: The application of the attribution rules does not impact on whose social insurance number is required on the information slip as the payor is not normally in a position to determine the extent to which the attribution rules apply. 2007 STEP Round Table Q. 2 Requirement for a Social Insurance Number In Technical Interpretation # 9812245 (dated June 22, 1998) the CRA indicated that the social insurance number (SIN) of a child (under age 18) is not required if the child's income is expected to be $2500 or less. ...

Selon ce même document, la valeur des marchandises vendues "would represent the fair market value of the goods manufactured or processed as determined by arm's length sales of these goods [...] under comparable conditions". ... According to this document, the value of the goods sold "would represent the fair market value of the goods manufactured or processed as determined by arm's length sales of these goods [...] under comparable conditions. ...

., 2010-0363131C6-- 2010 STEP Conference Q13 – gifts by will and 2011-0430131E5-- Subsection 118.1(5)—gift by will). ... The 2017 T4011 Guide – Preparing Returns for Deceased Persons on page 18, still includes the above administrative practice. ...

Would Canada view such US transition tax as an “income or profits tax” as referred to under subsection 126(7) of the Income Tax Act (“Act”) when applying the foreign tax credit (“FTC”) rules in the computation of the US citizen / Canadian resident individual? ... Grondin / Nicolas Bilodeau 2018-074881 ...

Enfin, tel que mentionné dans cette affaire, à la page 1691, il est possible d'éviter le problème de circularité du calcul de l'impôt de la Partie IV de plusieurs façons, entre autres, "..., notamment par la création d'une filiale ou en effectuant les rachats d'actions au cours d'années d'imposition différentes pour chacune des corporations. " Marc LeBlond 946-3261 Le 10 octobre 2003 2003-003008 ROUND TABLE ON FEDERAL TAXATION APFF- 2003 CONFERENCE Question 13 Circularity and Part IV Tax Part IV tax in the ITA is difficult to establish where, for example, there is a cross-redemption of shares (which results in a deemed dividend within the meaning of subsection 84(3) of the ITA) between two connected corporations and one of which has refundable dividend tax on hand (RDTOH). ...

The service standard for a Ruling is 90 business days commencing with the receipt of all information required from the client as outlined in Appendix A – Ruling Request Checklist of Information Circular IC 70-6R11, Advance Income Tax Rulings and Technical Interpretations (footnote 2) (IC 70-6). ... Remission of the service fee will be granted when the Ruling is issued, or the Pre-ruling Consultation is completed, subsequent to its service target date, as set out in Appendix H – Remissions of IC 70-6. ...

Yes; a description of the process and the required information is detailed in this response. 2022 CTF Annual CRA Round Table – November 29, 2022 Question 5: The New Proposed Critical Mineral Exploration Tax Credit Background In order for taxpayers to be eligible for the critical mineral exploration tax credit (“CMETC”) one of the requirements is that a qualified professional engineer or professional geoscientist provide certification within the 12-month period immediately preceding the time that the flow-through share (“FTS”) agreement is made, in prescribed form and manner, that the expense will be incurred pursuant to an exploration plan that primarily targets critical minerals. ... However, where proposed legislation results in an increase in benefits (for example, Canada child tax benefit) to the taxpayer, or if a significant rebate or refund is at stake, the CRA’s past practice has generally been to wait until the measure has been enacted. … Generally speaking, the CRA will not reassess if the initial assessment was correct in law. ...

Reasons: An exempt person defined in subsection 94(1) is excluded from the definition of resident beneficiary in subsection 94(1). 2023 STEP CRA Roundtable – June 20, 2023 Question 6: Non-Resident Trust and Canadian Charity A long-term Canadian resident becomes a non-resident and within 60 months, for reasons not related to Canadian tax, settles a non-resident trust for non-resident family members. ... Dawn Dannehl 2023-095957 FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 Pursuant to the definition in subsection 248(1) a “registered charity” must be resident in Canada. 2 The Act means the Income Tax Act R.S.C. 1985 (5th Supp.) c.1 as amended from time to time and consolidated to the date of this response and, unless otherwise expressly stated, every statutory reference herein is a reference to the relevant provision of the Act. 3 A trust to which paragraph 94(3)(a) applies is deemed to be resident in Canada only for the purposes listed in subparagraphs 94(3)(a)(i) to (x). 4 Resident contributor is defined in subsection 94(1) as, “ ‘resident contributor’ to a trust at any time, means a person that is, at that time, resident in Canada and a contributor to the trust...” ...

20 June 2023 STEP Roundtable Q. 12, 2023-0959591C6- Corporate Beneficiary and CDA Unedited CRA Tags 89(1) – definition of capital dividend account; 104(21) Principal Issues: 1. ... Reasons: The wording of the provisions in the definition of capital dividend account in subsection 89(1). 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 12. ...

In February 2024, the CRA published form T1521 – Election for a Pertinent Loan or Indebtedness (PLOI) under Subsection 15(2.11). In April 2024, the CRA also published form T2311 – Election for a Pertinent Loan or Indebtedness (PLOI) under Subsection 212.3(11). ...