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4 June 2024 STEP Roundtable Q. 8, 2024-1007841C6- Disposition of Property Held in a Bare Trust-- summary under Subparagraph 150(1.1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.1)- Paragraph 150(1.1)(b)- Subparagraph 150(1.1)(b)(ii) a disposition by a bare trust, or the trust’s winding-up, generally is not a disposition under the ITA A bare trust (not described in (a) to (e.1) of s. 108(1) – trust) holds no property in the year other than a Cdn.$10,000 government bond and money, not exceeding Cdn.$50,000 in the year, so that it satisfies s. 150(1.2)(b). ...

Although the ordinarily-inhabited condition under the principal residence definition would not generally be met for the Secondary Suite while being rented to third parties, where it was subject to the s. 45(2) election it could nonetheless qualify as the taxpayer’s principal residence for up to four taxation years during which the election remained in effect – so that the homeowner would be able to choose for such a year to designate the Secondary Suite rather than the balance of the property as that taxpayer’s principal residence. ...

., the actual capital cost grossed-up to $15,000,000 and multiplied by the 50% Class 43.2 rate); It claims the Nova Scotia Capital Investment Tax Credit (“NS CITC”) of 25% of the $10,000,000 capital cost, or $2,500,000 and receives it by way of credit or refund; It claims and receives the Clean Technology Investment Tax Credit (“Clean Tech ITC”) pursuant to s. 127.45, which is calculated as 30% of the capital cost, as reduced by the NS CITC, viewed as government assistance that it can “reasonably be expected to receive” (on December 31, 2024, receipt of the NS CITC is contingent on it receiving, by its filing-due date, an entitlement certificate); It claims an Atlantic Investment Tax Credit (“AITC”) pursuant to s. 127(9) of $750,000, being 10% of the capital cost, again reduced to $7,500,000 by the NS CITC “government assistance” – and receives the AITC by way of credit against federal tax payable in the current year or during the carryforward or carryback period. ...

The two deferred payments were not made on the agreed dates because of disagreements about the method for their computation. 21 months after the closing date, the parties agreed that a deferred payment of $50,000, rather than $200,000 + $300,000, would be paid. ...

Further … a personal guarantee of the amount owing under a vendor take-back promissory note by the controlling shareholder of the purchaser corporation would not, where the purchaser corporation has the capacity to make the scheduled payments under the promissory note (and absent any other factors indicative of de facto control), result in the holder having de facto control of the purchaser corporation. ...

Before concluding that (by virtue of the exception in s. 67.1(2)(c) s. 67.1(1) did not limit the deduction to the taxpayer for its incurring of the meal allowances and that such limitation instead applied to the purchasers respecting the cumulative amount of the meal allowances referred to in the interim invoice note, CRA indicated: The expression “amount … compensated” in s. 67.1(2)(c) was used in the sense of “paid or reimbursed”. ...

. … HBP participants who withdraw over more than one year will generally be contacted by the CRA to confirm details of their participation. ...

Assuming that an amount under the guarantee agreement became payable within 12 months after the time of the cessation of Aco’s business, s. 39(12) applied to all amounts repaid under the guarantee agreement – so that Mr. ...

In finding that the correction of the terms of the partition through the partial mortgage assumption by A did not produce proceeds of disposition to B (and before finding that the compensation to B for the excess interest payments he had made on such assumed mortgage amount produced a s. 12(1)(x)(iv) inclusion to him), the Agency stated: [W]ithin the framework of the out-of-court settlement agreement, Brother A and Brother B genuinely intended to correct the error that occurred during the partition … [and] they did not intend to pay compensation (a cash payment) to offset the inequality in the partition. ...

. … [I]n... Kaiser... 91 DTC 1057...the taxpayer tried [unsuccessfully] to convince the Tax Court that foreign taxes paid on employment income were deductible under subsection 20(12).... ...