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Summary of 2 February 2017 Quebec CPA Individual Taxation Roundtable, Q.1.3, 2016-0674821C6 Tr under s. 122.6 – cohabiting spouse or common-law partner. ...

Summary of 2016 Ruling 2016-0634031R3 under s. 118.1(1) – total charitable gifts. ...

Summary of 2015-0624611R3 under s. 89(1) – capital dividend account- (d) ande s. 83(2.1). ...

Summary of 1 March 2017 External T.I. 2016-0658431E5 under Treaties – Art. 13. ...

CRA considers that any FX loss realized by Parent on maturity of the loan would be denied by s. 261(21) given that the loan made by FA was on FAPI account – even if Parent had entered into a cross-currency swap to hedge its U.S. ...

The Directorate found that CRA was also authorized by s. 152(4)(b)(iii) to reassess so as to reallocate both the pre-TPA and additional TPA revenue among the provinces – apparently even though this might only affect relative provincial taxable income and not affect federal taxable income (given that the TPA reassessment had already occurred). ...

Neal Armstrong Summary of 16 January 2017 External T.I. 2016-0655701E5 under Treaties – Art. 5. ...

At the 2016 CTF Annual Conference, Q13, CRA indicated that this transitional rule is unavailable where a taxpayer’s only intangible asset was internally-generated goodwill with no cost – so that the taxpayer could not be said to have made or incurred an ECE in respect of the business, thereby ousting the election. ...

Summary of 20 April 2017 External T.I. 2016-0679721E5 under s. 125(7) – specified corporate income. ...

Summary of 13 June 2017 STEP Roundtable, Q.1 under s. 125(7)- specified corporate income – (b). ...