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(b) or (f) As part of its response to the question as to whether a guaranteed investment certificate or term deposit denominated in Canadian or foreign currency issued by a bank in Canada or a trust company a qualified investment for an RRSP, CRA stated: [I]n general, a guaranteed investment certificate or term deposit, denominated in Canadian or foreign currency and issued by a bank in Canada, would qualify as a bond, debenture, note or similar obligation” specifically described in paragraph (b) …. Furthermore, a guaranteed investment certificate, denominated in Canadian or foreign currency, issued by a trust company incorporated under the laws of Canada or of a province could qualify as a qualified investment under paragraph (f) …. ...

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 14, 2017-0708511C6 F- T1135 and 162(7) penalty-- summary under Subparagraph 152(4)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(a)- Subparagraph 152(4)(a)(i) failure to file a T1135 treated as a misrepresentation – but neglect etc. ground to be determined In 2015-0588971C6, CRA indicated that the proposition that “the late-filing penalty of $2,500 under subsection 162(7) applies automatically… is currently under study.” CRA has now indicated that having completed that study, it is: still of the opinion that [the penalty] applies automatically where all the conditions of that subsection are satisfied. … CRA went on to acknowledge the six-year normal reassessment period under s. 152(4)(b.2), and referenced the exception thereto for neglect etc., and stated: Failure to file Form T1135 when required by subsection 233.3(3) constitutes, in the CRA's view, a misrepresentation. ...

After indicating that the s. 248(1) definition of business was “intended to clarify and extend the ordinary meaning of the word ‘business’," CRA stated: … Stewart considered how to determine whether or not there is income from a source for the purpose of section 9. ... Ultimately, the question of whether the activities of a taxpayer constitute a "business" remains a question of fact …. ...

CRA responded: Generally split income … include[s] amounts that are included in a specified individual’s income in respect of a corporation, partnership or a trust … [and] does not include amounts that are included in the income of a specified individual as a result of the direct ownership of real property. ...

., and distributes the dividend to B Co (a beneficiary) to which A Co is connected – but they cease to be connected corporations by December 31 of that year. ... IV tax exemption did not apply to the dividend received by B Co since the s. 104(19) designation is considered to be effective only at the end of the trust’s taxation year – at which time they were no longer connected. ...

After indicating that this question “is still under review by the CRA,” it stated: In parallel, work is underway at the …OECD … to develop the Crypto-Asset Reporting Framework (the “CARF”), a standardized package that will include reporting requirements to tax administrations and exchange of information procedures related to taxpayers’ transactions with crypto-asset service providers. … A public consultation meeting will be held at the end of May 2022. ...

. … [T]he issuance of a note by a trust does not result in the beneficiary having the ownership of property which belonged to the trust and to which he had a right as beneficiary immediately before its distribution. Therefore subsection 107(2) cannot apply respecting the note for $150,000. … [T]he issuance of a note does not constitute the distribution of property of a trust to a beneficiary for purposes of paragraph (a) of the definition of cost amount in subsection 108(1). ...

After noting that one of the conditions for the application of s. 104(19) was that the amount be includible under s. 104(13)(a), 104(14) or 105 in the taxpayer’s income and before concluding that s. 104(19) would not apply, so that the s. 112(1) deduction would be unavailable, CRA stated: An employee trust … is a trust referred to in paragraph (a) of the definition of "trust" in subsection 108(1). ... Similarly, subsection 104(14) and section 105 do not apply …. A similar analysis would apply if the Trust was no longer an employee trust but instead was a trust governed by an employee benefit plan to which the corporation had contributed as an employer. ...

Is the capital loss as computed before the application of s. 40(3.6) attributed to X or to the protective trust, and is it added to the ACB of the trust's or X's shares – and would the answers change if all the shares were held by the trust? CRA responded (TaxInterpretations translation):...A loss which is deemed to be nil by virtue of paragraph 40(3.6)(a) is not attributable to anyone. … Assuming that after the redemption of the shares…held by the asset-protection trust, the trust continuously still holds at least one share…, the amount of the loss must be added in the calculation of the adjusted cost base of a share…held by the asset-protection trust immediately after the disposition…. ...

Is the income allocated to the other taxpayer in Situations 1 and 2 under ss. 74.1(1) and 103 required to be reimbursed by the taxpayer who received the income – and similarly re Situation 3, is B required to reimburse A for the sale proceeds received by him? CRA stated: [T]he provisions…mentioned...do not provide for a reimbursement obligation by a taxpayer where a benefit was allocated or when income was attributed to another taxpayer. … ...