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15 June 2022 STEP Roundtable Q. 14, 2022-0930221C6- Info on new T3 EFILE process-- summary under Paragraph 150(1)(c) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1)- Paragraph 150(1)(c) now efiling T3 returns CRA noted that its: EFILE web service is now accepting transmissions of T3 returns (currently limited to only 2021 and subsequent tax years T3RET, T3S, T3M, T3RCA & T3ATH-IND return types) and T1135 Foreign Income Verification Statements. ...

8 October 2010 Roundtable, 2010-0373291C6 F- Tuck-Under Transactions- Safe Income Extractions-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income can be extracted using tuck-under In the course of indicating that, in some instances, it would consider applying ss. 84(2) and 245(2) to tuck-under transactions, CRA stated: T]he CRA maintains its long-standing position that subsections 84(2) and 245(2) should not apply to a "tuck under" transaction to extract the safe income on hand relating to the interest of a corporate taxpayer in a target corporation …. ...

RDTOH and Dividend Refunds-- summary under Subsection 129(1.2) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1.2) " In response to a request for an update on its position on s. 129(1.2), CRA noted that it had issued favourable s. 129(1.2) rulings on post-mortem estate planning transactions (2004-008855, 2010-0377601R3 and 2012-0456221R3) and further stated that where the purpose test in s. 129(1.2) was met, s. 129(1.2) could technically apply to deny a dividend refund to a payer corporation even if tax was paid by the shareholder on the dividend received from the payer corporation. ...

. … 2012-047216117 dealt with the issue of whether the executors of an estate were empowered to make a gift to charities, and thus claim a deduction pursuant to subsection 118.1(3) in computing the tax payable by the estate. ...

See detailed summary under s. 108(1) – cost amount. ...

5 October 2012 Roundtable, 2012-0454201C6 F- Nouvelle Circulaire- Prix transfert international-- summary under Subsection 247(2) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(2) 2010 OECD Guidelines to be reflected in revised Transfer Pricing Memorandum – not revised IC 87R2 Does the CRA intend to issue a new version of IC87-2R that will reflect the new 2010 version of the OECD Guidelines? ...

. … Administratively, there is no requirement that the CRA extend the taxpayer relief provisions to elections other than those listed in section 600 of the Regulations. ...

. … Administratively, there is no requirement that the CRA extend the taxpayer relief provisions to elections other than those listed in section 600 of the Regulations. ...

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11 October 2013 APFF Roundtable, 2013-0495651C6 F- Revenu fractionné-- summary under Subsection 104(13) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(13) streaming of split and non-split income between trust beneficiaries A discretionary family trust with Father, Mother and a 15-year old Child as beneficiaries, holds a building with two premises – the first leased to an arm's length tenant; and the second, to a professional corporation of Father and Mother. ...