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. … Depending on the circumstances, the application of the presumptions in subsection 7(1.3) could result in the requirement of paragraph 110(1)(d.01) in respect of the acquisition of securities in the year of disposition not being satisfied. ...

After noting that “the will must require the executor … to distribute the bequeathed property to the designated legatee,” CRA stated: [A] gift the amount of which is left to the discretion of the executor or the deceased's legal representative is not a gift made by will. ...

CRA considers that any FX loss realized by Parent on maturity of the loan would be denied by s. 261(21) given that the loan made by FA was on FAPI account – even if Parent had entered into a cross-currency swap to hedge its U.S. ...

CRA indicated that the template S-Corp. agreements provides that the income of the S-Corporation that is deemed to be foreign accrual property income is to be determined under the Code, which will include the income of the QSSS – so that there is no need for the Canadian shareholder to enter into a separate S-Corp. agreement with respect to the QSSS. ...

Under element A of the formula in the CEC definition of CEC, the balance in Newco's CEC account as at December 31, 2003 was $500,000, reflecting a reduction for ½ of such s. 14(1)(b) inclusion. ...

Consequently, subsection 70(9.2) would not apply … Words and Phrases consequence of the death ...

. … The CRA is of the view that an obligation such as the one described in the above example is not an obligation described in paragraph 7000(1)(b) and therefore the provisions of subsection 12(9.1) do not apply. ...

14 September 2017 Roundtable, 2017-0703871C6- CPA Alberta 2017 Q9: PHSP for owner-managers-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) sole employee-shareholder unlikely to qualify for PHSP CRA considers that: In a situation where a corporation provides a self-insured HCSA for its only employee who is also its sole shareholder …, it is likely that the sole employee-shareholder would be reimbursed for the full amount allocated to him or her annually. ...

21 November 2017 CTF Roundtable Q. 10, 2017-0724291C6- Tax Shelters-- summary under Subsection 96(2.2) Summary Under Tax Topics- Income Tax Act- Section 96- Subsection 96(2.2) no rulings on at risk rules’ application to tax shelter LPs In indicating that it “will generally not issue an advance income tax ruling … with respect to a limited partnership financing arrangement involving the application of the at-risk rules in the context of a tax shelter, as defined in subsection 237.1(1),” CRA stated: Although the CRA does not verify the representations of fact at the time of the Ruling, they should be capable of verification at that time. ...

. … If the name does not match after several attempts then the authorization will be denied and they will be presented with a message for the owner to contact the CRA. ...