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29 January 2025- 11:19pm CRA releases the 3 December 2024 CTF Roundtable Email this Content CRA has released under the severed letter program the final version of all the questions and answers at the 3 December 2024 CTF Roundtable. ... Topic Descriptor 3 December 2024 CTF Roundtable Q. 1, 2024-1038181C6- Safe Income and Preferred Shares Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income of preferred shares issued on a s. 85 share-for-share exchange matches the safe income of the exchanged shares, and subsequently participates based on its dividend rate 3 December 2024 CTF Roundtable Q. 2, 2024-1038191C6- Subsection 55(2) and Intra-Corporate Dividends Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) CRA continues to be prepared to issue rulings dealing with the s. 55(2.1)(b) purpose tests 3 December 2024 CTF Roundtable Q. 3, 2024-1038151C6- Notifiable Transactions Income Tax Act- Section 212- Subsection 212(3.1) s. 212(3.1) generally inapplicable where immediate funder receives only common shares financing from ultimate funder Income Tax Act- Section 237.4- Subsection 237.4(4)- Paragraph 237.4(4)(b) B2B reporting engaged where loan from immediate NR parent (funded in turn in part with debt from ultimate parent) bears reduced (10%) withholding 3 December 2024 CTF Roundtable Q. 4, 2024-1038161C6- EIFEL and the Excluded Entity Exception Income Tax Act- Section 18.2- Subsection 18.2(1)- Excluded Entity- Paragraph (c)- Subparagraph (c)(i) 90% not applied as a strict threshold for determining “substantially all” 3 December 2024 CTF Roundtable Q. 5, 2024-1038171C6- EIFEL and ATI Calculation where Taxpayer has Non-Capital Losses Income Tax Act- Section 18.2- Subsection 18.2(1)- Adjusted Taxable Income- A- D- Paragraph D(b) not permitting taxable income to be negative in the ATI formula is producing anomalous results 3 December 2024 CTF Roundtable Q. 6, 2024-1038251C6- EIFEL- Pre-Regime Election and Amalgamations and Liquidations Income Tax Act- Section 87- Subsection 87(2.1)- Paragraph 87(2.1)(a.1) continuity treatment extends to the use of pre-regime capacity 3 December 2024 CTF Roundtable Q. 7, 2024-1038221C6- Post-Mortem Pipeline Bump Planning Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c)- Subparagraph 88(1)(c)(vi)- Clause 88(1)(c)(vi)(B)- Subclause 88(1)(c)(vi)(B)(I) estate beneficiary not considered to acquire 10% interest in estate company prior to deemed s. 88(1)(d.2) and (d.3) acquisition Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(d.2) an 11% estate beneficiary becomes a specified shareholder of the deceased’s corp. concurrently with its deemed acquisition under ss. 88(1)(d.2) and (d.3) 3 December 2024 CTF Roundtable Q. 8, 2024-1038201C6- Application of paragraph 55(2)(b) Income Tax Act- Section 55- Subsection 55(2)- Paragraph 55(2)(b) s. 55(2)(b) interpreted so as to avoid circularity 3 December 2024 CTF Roundtable Q. 9, 2024-1038271C6- Regulation 105 Income Tax Regulations- Regulation 105- Subsection 105(1) Reg. 105 applies amounts paid to a non-resident for services rendered in Canada even where those services have been subcontracted to a Canadian resident 3 December 2024 CTF Roundtable Q. 10, 2024-1038231C6- Intergenerational Business Transfers Income Tax Act- Section 84.1- Subsection 84.1(2.31)- Paragraph 84.1(2.31)(a) the prohibition against multiple use of the intergenerational transfer rules does not apply to simultaneous transfers 3 December 2024 CTF Roundtable Q. 11, 2024-1038241C6- Global Minimum Tax Act – Interpretation and Application of OECD Agreed Administrative Guidance Other Legislation/Constitution- Federal- Global Minimum Tax Act- Section 17- Subsection 17(6) CRA will administer s. 17(6) to push down taxes paid by indirect owner of reverse hybrid CE on income of the CE allocated to it, to the CE Other Legislation/Constitution- Federal- Global Minimum Tax Act- Section 3- Subsection 3(1) CRA will consult with Finance re potential amendments to catch up to OECD guidance in administering the GMTA 3 December 2024 CTF Roundtable Q. 12, 2024-1037751C6- Property flipping rules and corporate property transfers Income Tax Act- Section 12- Subsection 12(13)- Paragraph 12(13)(b) s. 12(13)(b) has no continuity rules for common reorganization transactions 3 December 2024 CTF Roundtable Q. 13, 2024-1038261C6- Standard Convertible Debentures and Part XIII Tax Income Tax Act- Section 212- Subsection 212(3)- Participating debt interest s. 214(7) excess received on the conversion of a standard convertible debenture generally is not participating interest Income Tax Act- Section 214- Subsection 214(7) FMV excess on conversion of a convertible debenture is deemed interest under s. 214(7) 3 December 2024 CTF Roundtable Q. 14, 2024-1037761C6- Availability of the Small Business Deduction Income Tax Act- Section 129- Subsection 129(4)- Income or Loss active business income includes income from property that (having regard to Ensite) is held principally for the purpose of producing active business income 3 December 2024 CTF Roundtable Q. 15, 2024-1030561C6- The Foix decision and hybrid sales Income Tax Act- Section 84- Subsection 84(2) Foix overruled a more restrictive approach to s. 84(2) in some earlier cases (and restricts Geransky) 3 December 2024 CTF Roundtable Q. 16, 2024-1038281C6- Indian Act Tax Exemption for Employment Income and Employees of a Limited Partnership Other Legislation/Constitution- Federal- Indian Act- Section 87 a partly owned LP of a 1st Nations band did not generate significant economic benefits to the reserve, its Indian employees were not exempted on off-reserve income ...