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7 October 2022 APFF Roundtable Q. 3, 2022-0942121C6 F- THRP- PRTA – Versement de dividendes imposables-- summary under Subsection 125.7(2.01) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(2.01) parent could pay a dividend in, say, Period 27, without adverse CEWS impact on Canadian sub Reference was made to the impact on the Tourism and Hospitality Recovery Program ("THRP") of the introduction of ss. 125.7(2.01) and 125.7(14.1) with effect for Periods 23 and beyond. ...

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 2, 2022-0936281C6 F- police d'assurance-vie & avantage-- summary under Subsection 246(1) Summary Under Tax Topics- Income Tax Act- Section 246- Subsection 246(1) taxable benefit where 2 Holdcos pay premiums on life insurance policies of which their jointly-owned sub is beneficiary unless s. 246(2) applies Suppose that two brothers resident in Canada each have a Holdco owning 50% of Opco and that, in order to fund the buy-sell agreement on the death of an ultimate shareholder, each Holdco has purchased insurance on the life of its sole shareholder, with Opco as the revocable or irrevocable beneficiary of both insurance policies. ...

7 October 2022 APFF Financial Strategies and Instruments Roundtable Q. 2, 2022-0936281C6 F- police d'assurance-vie & avantage-- summary under Expense Reimbursement Summary Under Tax Topics- Income Tax Act- Section 9- Expense Reimbursement premiums paid by parent on a sub’s life insurance policies are non-deductible even if reimbursed on income account Two brothers resident in Canada each have a Holdco owning 50% of Opco. ...

17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit”-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion Art. ...

15 September 2020 IFA Roundtable Q. 6, 2020-0853561C6- Subsection 212.3(9) & The GAAR-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) circular transactions to effect a s. 212.3(9)(b)(ii) PUC reinstatement abused that provision Canco (wholly-owned by NRco) acquired all the shares of FA1 for $100, thereby effecting a reduction of the paid-up capital (PUC) of the common shares of Canco by $100. ...

5 May 2021 IFA Roundtable Q. 7, 2021-0887521C6- Section 247, FAPI & Subsection 80.4(2)-- summary under Paragraph 247(2)(a) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2)- Paragraph 247(2)(a) a non-interest-bearing loan from a CFA to a NR sister of the Canadian taxpayer would generate imputed interest and FAPI to CFA, plus s. 80.4(2) application to sister A wholly-owned foreign subsidiary (FS) of CanCo uses funds generated from its operations to make a non-interest bearing loan to a foreign borrower (FB), which is wholly owned by the foreign parent (FP) of CanCo. ...

5 May 2021 IFA Roundtable Q. 7, 2021-0887521C6- Section 247, FAPI & Subsection 80.4(2)-- summary under Subsection 80.4(2) Summary Under Tax Topics- Income Tax Act- Section 80.4- Subsection 80.4(2) a non-interest-bearing loan from a CFA to a NR sister of the Canadian taxpayer generated double tax (FAPI and Pt. ...

3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 1, 2023-0976911C6 F- CELIAPP- Changement d'usage / FHSA- Change in use-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 146.6- Subsection 146.6(1)- Qualifying Withdrawal- Paragraph (d) a recent change of a home from rental to principal-residence use cannot ground an FHSA withdrawal An individual purchased a single-family home in 2020 for rental to a third party, in May 2023 opened and contributed $8,000 to an FHSA and then, after the tenant vacated, moved into the home as his principal place of residence on November 1, 2023, so that there was a deemed disposition and reacquisition of the property pursuant to s. 45(1)(a) on that date. ...

10 October 2024 APFF Roundtable Q. 2, 2024-1028371C6- Transfert intergénérationnel d’entreprise – nouvelles règles-- summary under Subparagraph 84.1(2.32)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(c)- Subparagraph 84.1(2.32)(c)(i) retention of special voting shares by parent would preclude access to s. 84.1(2)(e) exception A parent wishes to access the s. 84.1(2.31) or (2.32) rules regarding a transfer of Parent Inc. ...

10 October 2024 APFF Roundtable Q. 2, 2024-1028371C6- Transfert intergénérationnel d’entreprise – nouvelles règles-- summary under Subparagraph 84.1(2.32)(f)(ii) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(f)- Subparagraph 84.1(2.32)(f)(ii) s. 84.1(2.32)(f)(ii) not satisfied if substantial unpaid purchase price at end of 10 years A parent wishes to access the s. 84.1(2.32) rules regarding a transfer of the shares of Parent Inc. ...