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., charging) will reduce the operating expense benefit determined under paragraph 6(1)(k) … where such costs can be established. ...

10 November 2002 Roundtable, 2002-0156845 F- CONGRE 2002 APFF-- summary under Subsection 7(1.1) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(1.1) realization of s. 7(1.1) gain on shares’ disposition even though they had lost most of their value An employee exercised stock options in 2001 after the CCPC employer became a public corporation and the shares had substantially appreciated – and then sold the shares a year later when they had lost most of their value. ...

. … We suggest you make a submission to the Department of Finance. ...

CRA noted that this was similar to Example 9 of CRA’s split-income guidelines, and stated that they both could be considered to be actively engaged in the business – but indicated that this was a question of fact. ...

CRA indicated that there is no requirement that the replacement property be acquired after the former property is disposed of – so that the acquisition of the new property in advance of the disposition of the former property would not prevent it from being a replacement property for ss. 13(4.1) and 44(5) purposes. ...

3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 8, 2023-0976901C6 F- RPP survivor benefit flowing through a GRE-- summary under Subsection 104(24) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(24) income can be distributed to estate beneficiary by issuing a demand note to her CRA indicated that s. 104(24) would be satisfied regarding the distribution by an estate of a pension benefit received by it to the sole beneficiary (the surviving spouse) through the estate issuing a demand note to her “to the extent that the issuance of the note was permitted by the will and … the demand note was unconditional.” ...

4 June 2024 STEP Roundtable Q. 14, 2024-1011571C6- T3 Trust Instalments-- summary under Subsection 156(1) Summary Under Tax Topics- Income Tax Act- Section 156- Subsection 156(1) no change to administrative practice of not charging interest or penalties for insufficient instalment payments by trusts CRA indicated that its release of two new forms- the T3 INNS3, Trust Instalment Voucher and the T3AO, Trust Amount Owing Remittance Voucher – does not signify any change to its current administrative practice of not charging interest or penalties for insufficient instalment payments by trusts. ...

It is difficult to see how the current results obtained using pipelines do not invoke the same policy concerns that other non-arm’s length transfers do – for example, the inter vivos 84.1 transfers that are more explicitly covered in the changes to s. 84.1(2)(a.1). ...

. … [S]ubsection 94(10) will deem Mr. X to have made the contribution to Trust at a time other than a non-resident time for each taxation year commencing with the taxation year during which Mr. ... Z, a previous long term resident of Canada, became a non-resident in January 2007, in July 2010 made a contribution to a non-resident trust (the "Trust2") and in March 2015, became a resident of Canada – and that Trust2 has Canadian resident beneficiaries who are not successor beneficiaries. ...