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7 June 2019 STEP Roundtable Q. 14, 2019-0798511C6- TOSI and PBE-- summary under Subparagraph (a)(i) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Split Income- Paragraph (a)- Subparagraph (a)(i) subjecting dividend income paid to a preferred beneficiary to TOSI accords with tax policy – but the designation can be readily avoided The Summary portion of 2018-0759521E5 indicated that if a s. 104(19) designation is made respecting a preferred beneficiary income amount resulting from an election under s. 104(14), the amount would be includable in split income under para. ...

Thus, the home acquired in July 2019 could, if all the other conditions … are otherwise satisfied, qualify as a "qualifying home" for the purposes of the FHBTC. ...

Y receives a survivor payment more than 30 days after making her contribution but within the rollover period, she may request the exercise of Ministerial discretion …. ...

. … Comments made [in 2017] with respect to subsection 146(8.2) constitute an administrative concession and are applicable only with respect to that subsection. ...

CRA considers the date of payment of the foreign tax to be the relevant date for the purpose of section 126 – and, therefore, the date that the amount arose for the purpose of s. 261(2)(b). ...

XXIV of the Canada-US Treaty – and took the view that this meant that a Canadian resident was subject to the “paid” requirement of s. 126. ...

. … In this case, the leasing activity does not appear to be free from personal aspects and it would be necessary to consider whether it is carried on in a sufficiently commercial manner so as to establish the existence of a source of income. ...

After referring to the initial residence unit as Unit 2 and the expanded unit as Unit 3, CRA stated: The taxpayer will therefore have to file two worksheets and two T2091 forms … if the taxpayer wishes to designate Unit 2 and Unit 3 as his principal residence for the applicable years. ...

After noting that it was necessary to report the preconverted living unit and the expanded unit separately in claiming the principal residence exemption, CRA stated: … [A]n allocation of the adjusted cost base ("ACB") and the proceeds of disposition of a property based on the size of each unit is, in some cases, that of a reasonable allocation. ...

. … [T]his subsection can apply to an amount of interest received from a trust and included in computing the income of a specified individual, to the extent that all other conditions for application of that paragraph are satisfied. ...