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STEP CRA Roundtable – June 2014 QUESTION 8. Transfer of property by a personal trust to a beneficiary A Canadian-resident trust that meets the definition of a "personal trust" in subsection 248(1) of the Act holds property that has appreciated in value since its acquisition by the trust. ...

12 June 2012 Roundtable, 2012-0442991C6- 2012 STEP Question 12 Principal Issues: General comments regarding the audit of high net worth individuals Position: CPB provided general comments STEP CRA Roundtable – June 2012 QUESTION 12 Could the CRA comment on its progress to date with respect to its audit focus on high net worth individuals? ...

CLHIA 2015 Roundtable Question 2 – Interaction of 95(2)(a.1) and 138(2) Consider a case where a corporation (Canco) resident in Canada and its wholly-owned foreign affiliate (FA) each carry on a life insurance business.   ...

Paragraphe 40(3.4): Conclusion — Objet: Participations dans une société de personnes Question 8 Lorsqu'une société de personnes a disposé de biens qui ont été assujettis à la règle sur la minimisation des pertes prévue au paragraphe 40(3.4), la fin de ce paragraphe prévoit que pour l'application de l'alinéa 40(3.4)b), la société de personnes est réputée continuer d'exister. ...

Reasons: See response CICA CRA Roundtable- September 2012 Question 9 – RRSP prohibited investments and warrants Background A registered retirement savings plan (RRSP) holds shares of a particular corporation. ...

STEP CRA Roundtable – June 18 2015 Question 1. Graduated Rate Estate-Taxation Year A graduated rate estate (GRE) obtains graduated tax rates for a period of 36 months. ...

IFA Roundtable, May 2014 Question 3(c) Question 3(c): Upstream Loan Rules – Back-to-back Loans In some foreign affiliate groups, one entity in the group provides cash management services to the other members of the group, pooling cash balances received from group members and making advances to other members of the group, generally on a short term basis. ...

STEP CRA Roundtable – June 2014 QUESTION 16- Stock Options at Death Paragraph 7(1)(e) provides that where an employee has died and the employee held unexercised stock options prior to their death, a benefit equal to the value of the stock options immediately after death minus any amount paid to acquire the options, is deemed to be received by the employee in the year of death. ...

Position: The version that provides the most favourable result for taxpayers Reasons: Consultations with Swiss and Canadian Competent Authorities and Finance Canada. 2015 International Fiscal Association Conference CRA Roundtable Question 12 – Canada-Switzerland Tax Convention: Article 10(2)(a) Article 10(2)(a) of the Canada-Switzerland Tax Convention (the "Swiss Treaty") restricts Canada's right to tax dividends paid by Canadian-resident companies to Swiss-resident companies to a maximum of 5 per cent of the gross amount of the dividends if, inter alia, the dividends are paid to a company that "owns at least 10 per cent of the voting stock and of the capital of the company paying the dividends". ...

STEP CRA Roundtable – June 10, 2016 QUESTION 2. Graduated Rate Estates and Multiple Wills If someone has a second will pertaining to foreign assets, and the domestic executors either do not know about this second will, or cannot deal with the foreign executors on a timely basis, would the status of the estate as a graduated rate estate (“GRE”) be invalidated if only the domestic executors elected for the estate to be a GRE? ...