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26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) drop-down of FA shares to non-share FA deemed to be for share consideration S. 95(2)(c) which, insofar as relevant to the question of how it dovetails with s. 93.2, is essentially identical to s. 85.1(3). ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election-- summary under Subsection 104(14) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(14) preferred beneficiary election and qualified disability trust election potentially can coexist Each of four grandparents of a disabled grandchild establishes a trust for the grandchild individual under their will, with one of the trusts being intended to be a qualified disability trust (“QDT”). ...

12 April 2016 External T.I. 2015-0595461E5- Australian Super Fund & T1135-- summary under Exempt Trust Summary Under Tax Topics- Income Tax Act- Section 233.2- Subsection 233.2(1)- Exempt Trust Australian Superannuation Fund not an exempt trust due to taxability 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. ...

22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution-- summary under Clause 95(2)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) inter-affiliate loan generating deemed active business funded out of an interest-free loan from Canco A wholly-owned foreign affiliate (“Luxco1”) of Canco held 1/3 of the shares of a corporation ("NRco"), which was resident in a Treaty country and carried on an active business there. ...

7 October 2016 APFF Roundtable Q. 11, 2016-0652941C6 F- Contrat de location / Capital lease-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation FMV of rights under a lease must be included Is the asset recorded in the financial statements as a capital lease considered as an asset used in an active business for purposes of the definitions of a qualified small business corporation share or of a small business corporation? ...

22 December 2016 External T.I. 2015-0608201E5 F- Capital distribution from trust & NR4-- summary under Regulation 202(1)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 202- Regulation 202(1)- Regulation 202(1)(c) all capital distributions made by Canadian-resident trusts to a non-resident beneficiaries must be reported on NR4s Does Reg. 202(1) require a Canadian-resident trust to report a capital distribution to a non-resident capital beneficiary? ...

29 November 2016 CTF Roundtable Q. 1, 2016-0669301C6- GAAR & 21-year rule planning-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) avoidance of 21-year rule through 107(2) transfer to corporate beneficiary A discretionary resident trust that is approaching its 21st anniversary distributes property with an unrealized gain to a corporate beneficiary that is wholly owned by a newly-established discretionary trust. ...

29 April 2008 External T.I. 2006-0215891E5 F- Partnership Interest & Departure Tax-- summary under Subparagraph 220(4.5)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(4.5)- Paragraph 220(4.5)(a)- Subparagraph 220(4.5)(a)(i) s. 85(1) rollover of the property triggered the s. 220(4.5) deferred tax On his emigration from Canada, Mr. ...

29 April 2008 External T.I. 2006-0215891E5 F- Partnership Interest & Departure Tax-- summary under Paragraph 85(1.1)(b) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1)- Paragraph 85(1.1)(b) partnership interest is eligible property After emigrating from Canada, an individual transferred his interest in a real estate partnership on a s. 85(1) rollover basis to a corporation of which he was the sole shareholder. ...

21 September 2007 External T.I. 2007-0229191E5 F- Agent de voyages & impôt de la partie I.3-- summary under Subparagraph 181(3)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3)- Paragraph 181(3)(b)- Subparagraph 181(3)(b)(i) customer advances received by travel agents and reported as deferred revenue in their balance sheets were required to be included in taxable capital even though amounts held in trust Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them in a trust account, and also, in their year end balance sheets, reported the current balances in the trust accounts as assets and also as liabilities, labelled as "customer deposits and deferred revenue". ...