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Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.2 under s. 261(2)(b). ...

Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.7 under s.146.6(15)(a). ...

Under CRA’s arrangement made in 1991 with the Canadian Dental Association, a dentist registrant could, for each reporting period in a fiscal year, use an estimate up to a maximum of 35% of the total consideration charged for orthodontic treatments to represent the consideration for the supply of orthodontic appliances, and claim ITCs on that basis – but then, at the end of the fiscal year, was required to perform a reconciliation based on the actual amounts charged for orthodontic appliances, and adjust the ITC claims for the year accordingly (keeping in mind that charges for cosmetic services also generated ITCs). ...

Summary of 15 July 2024 External T.I. 2023-0990221E5 under s. 54 – principal residence. ...

Summary of 2021 Ruling 2021-0887611R3 under s. 248(1) – SDA. ...

CRA also was somewhat mystified by the question, and indicated that it did not read these provisions as creating circularity – but indicated that, in any event, if such a possibility did exist, it would take a purposive approach to avoid an absurd result. ...

However, on the death of Daughter2, ½ of the Fund property had been distributed in accordance with the Fund terms to her issue. ...

Summaries of 5 September 2024 External T.I. 2024-1022711E5 under s. 118.1(1) – total charitable gifts- (c)(i)(A) and s. 152(4.2). ...

Summary of 2024 Ruling 2024-1008821R3 F under s. 55(1) – distribution. ...

Regarding the payment of “interest” on any preferred shares held by members, this would constitute in substance a distribution of the cooperative’s profits to them and, thus, be offside – and indeed, the mere issuance by it of such shares would put it offside even if no such interest was paid. ...