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Summary of 4 June 2019 Internal T.I. 2018-0783441I7 F under Treaties Income Tax Conventions – Art. 13. ...

However, s. 147.4(1) does not apply to annuities purchased from foreign pension plans, so that a retiree- whose former non-resident employer determined to wind-up a foreign pension plan by using funds in the plan to purchase annuity contracts for each retired member – was required under s. 56(1)(a)(i) to include the full fair market value of the annuity in income in the wind-up year. ...

3 November 2019- 11:25pm CRA will consider forms of security other than an LC for assessed taxes and interest Email this Content ETA s. 314(2) provides that “the Minister shall accept security, in an amount and a form satisfactory to the Minister … for payment of any amount that [has been objected to].” ...

Summaries of 28 February 2019 CBA Roundtable, Q.11 under ETA s. 256.2(3) and s. 123(1) – builder. ...

CRA indicated that there is no requirement that the replacement property be acquired after the former property is disposed of – so that the acquisition of the new property in advance of the disposition of the former property would not prevent it from being a replacement property for ss. 13(4.1) and 44(5) purposes. ...

15 January 2020- 12:32am A Canco with excess credits could use them to offset the imputed interest on a PLOI to its NR parent Email this Content A Canadian high tech company with operating losses and no immediate use for SR & ED credits could get more benefit from them by making a loan to its non-resident parent which is elected under s. 15(2.11) to be a PLOI and then use such credits to offset the imputed interest on the PLOI. ...

Summary of May 2019 CPA Alberta CRA Roundtable, ITA Session – Q.20 under ITA s. 70(2). ...

Summary of 2020 Ruling 2019-0799981R3 under s. 248(1) – disposition. ...

. … [O]ver 150 audits of taxpayers have been completed, nearly $60 million has been assessed of which approximately $20 million has been collected and over 300 audits of taxpayers are in progress. ...

Summary of 20 October 2020 External T.I. 2020-0856781E5 under s. 125.7(1) – eligible remuneration. ...