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STEP CRA Roundtable – June 13 2017 Question 4. US Grantor Trust A Canadian resident individual (Mr. ...

Reasons: See comments. 2018 CTF Annual Conference CRA Roundtable Question 9: TOSI – Excluded Amount and the Non-Related Business Exception Under the definition of “excluded amount” in subparagraph 120.4(1)(e)(i), an amount will not be split income of a specified individual who has attained the age of 17 years before a taxation year in circumstances where it is not derived directly or indirectly from a “related business” in respect of the individual for the year. ...

Reasons: Wording of the provision. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 5. ...

Position: General comments provided. 2024 CTF Annual Conference CRA Roundtable Question 12 – Property flipping rules and corporate property transfers The flipped property rules contained in subsections 12(12) to 12(14) of the Act (the “Flipped Property Rules”) provide a deeming rule (in subsection 12(12) of the Act) that results in a gain on the disposition of a housing unit that is flipped property being fully taxable as business income. ...

Position: Based on the policy objectives set out in the explanatory notes for the transition rules and the amendments to section 87 and 88 and the coming into force of the amendments it is reasonable to extend the application of paragraph 87(2.1)(a.1) and subsection 88(1.11) to the transitional amounts applicable in the pre-regime period notwithstanding these provisions do not explicitly refer to the terms used in the pre-regime transition rules. 2024 CTF Annual Tax Conference CRA Roundtable Question 6 – EIFEL- Pre-Regime Election and Amalgamations and Liquidations The legislation enacting sections 18.2 and 18.21 of the Act (which are the main provisions of the Excessive Interest and Financing Expenses Limitation Regime or EIFEL rules) includes a pre-regime election (footnote 1) in the coming into force provision that allows a taxpayer to elect to calculate its excess capacity for each of the three taxation years (the pre-regime years) immediately preceding its first taxation year (the first regime year) in respect of which the EIFEL rules apply. ...

Question 8- Interaction of Subsections 250(5) & 212(13.2) A U.S. corporation wishes to acquire an existing business in Canada and decides, for U.S. tax reasons, to establish a wholly-owned U.S. subsidiary ("Subco") to purchase the business. ...

Department's Position Some of the factors the Department would consider are: 1)     the identity of the employees whose lives are insured as compared to those to be provided benefits under the SERP; 2)     the timing of the acquisition of the insurance and the setting up of the SERP; 3)     the extent of the monetary coverage under the insurance as contrasted with the value of the benefits under the SERP; 4)     reasons (other than the existance of the SERP) for the employers purchase of insurance such as; (i)     "key man" insurance acquired as coverage for losses or damages the employer might suffer on the death of the employee; and (ii)     life insurance policies acquired solely to pay benefits in the event of the death of an employee. ... CALU Annual Meeting Questions for Revenue Canada RETIREMENT COMPENSATION ARRANGEMENTS 10.      ... Q.     (d)  The retirement income benefits under the SERP are funded by the employer on a pay-as-you-go basis.  ...

Bien que le père ait dans cet exemple le contrôle effectif de la société par le biais des actions catégorie B à votes multiples, fils 1 et fils 2 contrôlaient chacun 50 % des actions catégorie A qui représentaient plus de 40 % du nombre d'actions émises et en circulation comportant un droit de vote, soit 500 actions sur un total de 1 100 (45 %). ...

Nous aimerions savoir ce que l'ARC entend par " termes généraux ordinairement retrouvés dans un acte de fiducie ". ...

Paragraph (a) of the definition of “reportable transaction” in subsection 237.3(1) of the Act generally describes a fee that is: • based on the amount of the tax benefit from the avoidance transaction or series; • contingent on obtaining the tax benefit from the avoidance transaction or series; or • attributable to the number of participants in the avoidance transaction or series (or a similar avoidance transaction or series), or the number of persons who have been provided access to advice or an opinion given by an advisor or promoter regarding the tax consequences of the avoidance transaction or series (or a similar avoidance transaction or series). ...