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• NRCo owns Forco. Forco owns 100% of a Canadian operating subsidiary (CanOpco). ... " CRA also would need to consider the business activities of: · the CRIC; · all corporations resident in Canada with which the CRIC does not at the investment time, deal at arm's length; · the subject corporation; · all subject subsidiary corporations, as that term is described in s. 212.3(16)(a); and · all non-resident corporations with which the CRIC, at the investment time, does not deal at arm's length, other than any corporation that is, immediately before the investment time, a controlled foreign affiliate of the CRIC for the purposes of s. 17. ... Official Response 23 May 2013 IFA Round Table, Q. 6h, 2013-0483751C6 Q. 7 – Thin capitalization • Assume that a Canadian subsidiary has two loans outstanding to specified non-residents: its US Parent and a UK related company. ...

SECTION 156 ELECTION Q.11- Use of a Newco – Section 156 Election Reply Q.12- Section 156 and Permanent Establishments Reply Q.13- Section 156 Election – Input Tax Credit Claims Reply Q.14- Section 156 and Partnerships Reply D. ... DROP-SHIPMENT RULES Q.36- Drop-Shipments – Subsection 179(4) Reply Q.37- Drop-Shipments – Leasing Arrangement Reply Q.38- Drop Shipments Rules – Interplay with Real Property Law Principles of Affixation Reply Q.39- Drop-Shipments – Carrying on Business Reply Scenario 1 Scenario 2 I. ... Financing Part A When – if at all – would a “financing lease” be considered a “loan” (i.e., exempt financial service) for GST purposes? ...

ELECTIONS Q.10- Late-filed Section 167 Elections CCRA Comments Q.11- Section 167 Election – Impact of Amalgamation CCRA Comments Q.12- Section 167 Election – Interpretation Facts Question CCRA Comments Q.13- Joint Venture Elections – Bare Trusts CCRA Comments D. ... OTHER Q.37- Fruit Juices CCRA Comments Q.38- Telecommunication Services – Fibreoptic Cable CCRA Comments Dark Fibre Lit Fibre Dim Fibre Q.39- New Housing Rebate – 254(2)(e) – Title Taken in Different Name CCRA Comments Q.40- Capital Property – All or Nothing Approach CCRA Comments Q.41- “Hot” Audit Issues and Current Cases CCRA Comments Q.42- Business Numbers CCRA Comments Amalgamations Partnerships Q.43- Closely Related Persons CCRA Comments A. ... Q.39- New Housing Rebate – 254(2)(e) – Title Taken in Different Name Is the new housing rebate under s. 254 available if title is taken in the name of a person other than the one who signed the Agreement of Purchase and Sale as purchaser? ...

Email this Content 27 October 2020 CTF Roundtable Q.1 – ACB increase in s. 55(3)(a)/88(1) reorg Preliminary Response Official Response Q.2 – Consolidation of safe income in a corporate group Preliminary Response Official Response Q.3 – Safe Income on Reorganization Preliminary Response Official Response Q.4 – Sale of taxable Canadian property by a partnership Preliminary Response Official Response Q.5 – Art. ... Treaty where further French layer Preliminary Response Official Response Q.6 – MLI and PPT Preliminary Response Official Response Q.7 – Use of cottage by children of settlor of AET/JST/CLPT Preliminary Response Official Response Q.8 – SDA rules and formula-based appreciation plans Preliminary Response Official Response Q.9 – UK LLPs as corporations Preliminary Response Official Response Q.10- Refreezes and s. 74.4(2) attribution quantum Preliminary Response Official Response Q.11 – Refinancing prescribed rate loans and attribution Preliminary Response Official Response Q.12 – Impact of COVID-19 on Previous APAs/Current MAPs Preliminary Response Official Response Q.13 – Reimbursement of Equipment Preliminary Response Official Response Q.14 – Section 86 Reorganization of Capital Preliminary Response Official Response This provides the text of the written questions that were posed, and summaries of the CRA oral responses, at the CRA Roundtable webinar hosted on 27 October 2020 by the Canada Tax Foundation. ... Official Response 27 October 2020 CTF Roundtable Q. 4, 2020-0862451C6- Sale of TCP by a partnership Q.5 – Art. ...

Email this Content 3 December 2019 CTF Roundtable Q.1 – Application of Multilateral Instrument (MLI) PPT Preliminary Response Official Response Q.2 – Translation under s. 126 of foreign taxes paid Preliminary Response- Q.2(a) Preliminary Response- Q.2(b) Official Response Q.3 – Translation of s. s. 55(5)(d)(i) TFSB at SIDT Preliminary Response Official Response Q.4- Ss. 84.1(1)(b) and 129(1)(a) Preliminary Response Official Response Q.5- S. 212.1(6) and post-mortem pipelines Preliminary Response Official Response Q.6- Distribution of TCP by resident trust to NR-owned corporate beneficiary Preliminary Response Official Response Q.7 – S. 120.4(1.1)(b)(ii) where share distribution by inter vivos trust on death Background – before Mr. ... In Scenario 1, the exchange rate of the US dollar is US $1 = CDN $1 at Time 1 and US $1 = CDN $1.2 at Time 2 At Time 2 Can Opco pays a dividend of $120 to Can Holdco In Scenario 2, the exchange rate of the US dollar is US $1 = CDN $1.2 at Time 1 and US $1 = CDN $1 at Time 2 At Time 2 Can Opco pays a dividend of $100 to Can Holdco. ... This implies a degree of correlation or direct substitution – one might say a “causal relationship” – between the disposition of the former property and the acquisition of the new one. ...

COPYRIGHT is reserved jointly to the CRA and the CBA Commodity Tax, Customs & Trade Section. ... CRA Response For the fiscal year 2008 – 2009 the following are the summary results: Summary of the 2008- 2009 fiscal year Total Income Tax Disclosures = 9,907 Total GST/HST Disclosures = 1,486 Total All = 11,393 Federal Tax = $392,384,192 Tax = $182,438,898 Total Tax = $574,823,090 There has been a small decline in GST/HST disclosures from previous years. For the fiscal year 2009 – 2010 to date the following are the summary results: Total Income tax and GST/HST disclosures = 10,000 Income change = $1.7Billion As an Agency we have reviewed the GST/HST WASH transactions policy. ...

Email this Content 5 May 2021 IFA Roundtable Q.1 – COVID 19 and CRA Guidance Post September 2020 CRA Response Official Response Q.2- Multilateral Instrument (“MLI”) CRA Response Q.3 – Application of subsection 261(5) to the $5M threshold of subsection 247(3) CRA Response Official Response Q.4 – Section 247 Post Cameco FCA decision CRA Response Official Response Q.5 – Applicability of subsection 247(7) CRA Response Official Response Q.6 – Arbitration CRA Response Q.7- Section 247, FAPI and Subsection 80.4(2) CRA Response Official Response Q.8- Application of 90(9)(b)&(c) CRA Response Q.9 – Income Tax Rulings Directorate – Remissions CRA Response Official Response Please note that the following questions and answers are not official and are subject to change until they are published by CRA. ... Cameco Corporation, 2020 FCA 112 upholding the Tax Court of Canada’s decision (“ Cameco ”)? ... Q.9 – Income Tax Rulings Directorate – Remissions The fees charged by the CRA for providing an advance income tax ruling or a supplemental ruling (“Ruling”), and a consultation in advance of a Ruling (“Pre-ruling Consultation”), are governed by the Service Fees Act. ...

Email this Content 28 May 2015 IFA Roundtable Question 1 – George Weston: hedging impact Notes From Presentation Official Response Question 2- GAAR and treaty shopping Notes From Presentation Official Response Question 3 – Entity classification/LLLPs Notes From Presentation Official Response Question 4 – Upstream loans: s. 90(9) deduction Part A Part B Part C Notes From Presentation Official Response Question 5 – Back-to-back loans: “because” test Notes From Presentation Official Response Question 6 – s. 95(2)(a)(ii)(D) and contribution of capital Notes From Presentation Official Response Question 7 – FA mergers and deficit double counting Notes From Presentation Official Response Question 8 – S. 39(2.1) and s. 261(10) inclusion Notes From Presentation Official Response Question 9 – s. 95(2)(i) re purchase note Notes From Presentation Official Response Question 10 – 111(4)(e) step-up and 212.3(2) Notes From Presentation Official Response Question 11 – FA borrows to pay dividend Notes From Presentation Official Response Question 12 – Conflicting versions of Swiss Treaty Notes From Presentation Official Response Presentation by Phil Halvorson (of Finance until 1 May 2015, but in a non-representative capacity) on BEPS Question 1 – George Weston: hedging impact The Tax Court of Canada recently rendered its decision in the George Weston Ltd. ... Official Response 28 May 2015 IFA Roundtable, Q. 9, 2015-0581581C6 Question 10 – 111(4)(e) step-up and 212.3(2) Following an acquisition of control, paragraph 111(4)(e) permits a taxpayer to make a designation in respect of certain capital property in order to deem a disposition and reacquisition of that capital property. ... Official Response 28 May 2015 IFA Roundtable, Q. 10, 2015-0581641C6 Question 11 – FA borrows to pay dividend Paragraph 95(2)(a) of the Act re-characterizes, in various circumstances, amounts that would otherwise be income from property of a foreign affiliate as income from an active business. ...

Please provide your suggestions on this matter to {HYPERLINK " mailto:Rick.Power@ccra.adrc.ca "}. ... Q.10- Damage Payments – Section 182 Facts/Background Example No. 3 of Policy Statement P-218R, entitled "Tax status of damage payments – whether or not within subsection 182(1) of the Excise Tax Act", states: " Facts 1. ... Although Company B does not have control of Company A, it has 90 % or more of the value ($100 / $110) and number (100 / 110) of voting shares. ...

Please provide your suggestions on this matter to {HYPERLINK " mailto:Rick.Power@ccra.adrc.ca "}. ... Company A would be controlled for income tax purposes by Company C because it holds more than 50% of the voting rights of Company A (10 X 100 = 1000 / 1100). ... Although Company B does not have control of Company A, it has 90 % or more of the value ($100 / $110) and number (100 / 110) of voting shares. ...