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17 November 2015 Roundtable, 2015-0613821C6- TEI question on section 55-- summary under Paragraph 55(2.1)(b) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) regular dividends not in excess of return on comparable listed shares not included/ "significant" measured in dollar or % TEI members remain concerned that, because all dividends result in a reduction of the fair-market value of shares held by the dividend payor and increase the cost of properties held by the dividend recipient, the CRA may try to reassess ordinary course dividends on the basis that a purpose of every dividend is a tainted purpose. ...

. … [T]he services of the employee assistance program that are counseling or advice respecting areas other than those specified in clauses (A) and (B) of subparagraph 6(1)(a)(iv), would not come within the exception provided by paragraph 6(1)(a)(iv). ...

Shareholder would have to maintain that PUC balance in € for the purposes of determining its CTRs. ...

. … In the described situation, although each of the building's units was subject to a change of use in Year 11, the relation between the use regularly made by the taxpayer of the property for gaining or producing income and the use regularly made of the property for other purposes did not change during the year. ...

[T]he deductions [under s. 153(1)(j)] are … made from the lump sum payment and designated as being for the account of the person receiving the amount, being the RRSP annuitant. ...

. … The CRA has already concluded in some of these types of cases that avoidance transactions are caught by subsection 245(4) and that the general anti-avoidance rule applies. ...

. … The GST, HST, QST or provincial tax portion, if any, of the amount paid should not be reported on the T4A slip since it is not an amount under subsection 153(1) and is not required to be included in computing the recipient's income under the Act. ...

. … [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...

. … [T]he CRA will examine any situation that involves a corporate group and where the life insurance proceeds included in a corporation's capital dividend account is not reduced by the adjusted cost base of the policy. ...

LLC that is a foreign affiliate and has a single member which is a regarded U.S. corporation should compute its “earnings” in accordance with Reg. 5907(1) – earnings- s. ...