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Summaries of 17 May 2022 IFA Roundtable, Q.1 under Treaties- Income Tax Conventions – Art. 4 and ITA s. 2(1). ...

Summary of 17 May 2022 IFA Roundtable, Q.8 under s. 248(1) – corporation. ...

30 May 2022- 11:03pm CRA applies the proposition (regarding a s. 90(3) PUC distribution election) that a partnership cannot be a related person Email this Content A limited partnership (LP)- whose 90% general partner is FA1 (held by Canco1) and whose 10% limited partner is FA2 (held by Canco2, which is related to Canco1) – receives a paid-up capital distribution from its wholly-owned subsidiary (FA3). ...

CRA noted the presumption in Gustavson Drilling [1977] 1 S.C.R. 271 that “statutes are not to be construed as having retrospective operation unless such a construction is expressly or by necessary implication required by the language,” and found that there was no such “necessary implication” in the Bill, so that the amendments “apply only to dispositions that occur on or after … June 29, 2021.” ...

CRA indicated, given that this provision requires that the election be made in the trust’s “return of income … for its first taxation year,” that it will accept an election filed under s. 104(4)(a)(ii.1) only if it is made in the trust’s return of income filed for its first taxation year- regardless of whether that return is filed on time or late. ...

10 July 2022- 11:07pm CRA indicates that a GRE’s taxation year terminates early when it is wound up Email this Content CRA noted that s. 249(1)(b) defines the taxation year of a graduated rate estate (GRE) to be the period for which the accounts of the estate are made up for purposes of assessment under the Act and that this paragraph, when combined with s. 249(5), causes the taxation year to cease when the period of accounts ends – which CRA considers to occur when the GRE is wound up or terminated. ...

The amount of the allowable capital loss … is then still determined under the ordinary rules in section 38. ...

CRA indicated that, under ETA s. 182, Aco is deemed to have collected the GST/HST as part of the liquidated damages amount, which is deemed to be consideration for a taxable supply by it, and Bco would be deemed to have paid that GST/HST (notwithstanding that Cco is the actual payer) – so that Bco (not, Cco) would be able to claim an ITC for the deemed GST/HST payment if the usual conditions in s. 169 were satisfied. ...

Summary of 22 December 2022 Internal T.I. 2020-0856411I7 F under s. 125.7(1) – eligible remuneration. ...

Summaries of 7 April 2022 CBA Roundtable, Q.3 under ETA s. 191(3) and s. 123(1) – real property. ...