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16 November 2011 External T.I. 2011-0419191E5- Foreign Intermediaries & Canadian Owners-- summary under Subsection 215(6) Summary Under Tax Topics- Income Tax Act- Section 215- Subsection 215(6) breach of undertaking Where a foreign financial intermediary ("FFI") has represented to a Canadian financial institution ("CFI") that the beneficial owners of securities in a subaccount are eligible for a 0% rate of withholding based on Treaty exemptions and CFI later learns that there are Canadian beneficial owners in those accounts, CFI should withhold at a 25% rate as FFI has breached its undertaking to provide a replacement certificate which is accurate. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...

2006 Ruling 2004-0106101R3- Class of German Arrangement & Treaty Benefits-- summary under Subsection 104(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(1) German real estate investment fund treated as trust Ruling that an open-end real estate fund established under the Investment Companies Act (Germany) (and to be continued under the Investment Act (Germany)) would be treated as an inter vivos trust that was not a personal trust for purposes of the Act in respect of its proposed investments in a Canadian partnership. ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Paragraph 104(4)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(4)- Paragraph 104(4)(a) CRA generally will ignore any premium that could be attributed to controlling non-participating preference shares, for purposes of subsection 70(5) of the Income Tax Act (the "Act"), where the shares were held to protect the deceased's economic interest in the corporation. ...

3 March 2015 External T.I. 2014-0519981E5 F- Donation avec charge / Gift with a charge-- summary under Property Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Property real estate property is one property Before considering the treatment under ss. 69(1)(b)(ii) and s. 69(1)(c) of a gift of a real estate property that is charged with a hypothec, CRA stated: [A]n immovable is normally considered as a single and unique property at least where such property is not the object of a legal partition into two or more distinct properties. ...

5 October 2012 Roundtable, 2012-0453201C6 F- Règles d'attribution- séparation & décès-- summary under Subsection 13(1) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(1) recapture from rental property is property income from that property Before finding that there was no attribution of recapture of depreciation by virtue of the exception from the application of s. 74.1(1) contained in s. 74.5(3)(a), CRA stated, in its summary: [T]he nature of recapture of depreciation is analogous to the nature of the depreciation expense that was claimed in the past. ...

3 December 2013 TEI Roundtable, 2013-0510851C6- 2013 TEI – Question 9: Tax residency certificates.-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) no residency certificates for partnerships Would CRA be willing to issue Canadian tax residency certificates in the name of a Canadian partnership on the basis of the Canadian residency of all its partners? ...

25 April 2014 External T.I. 2013-0515621E5 F- Frais de voyage / Travelling expenses-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) benefit where employer pays costs of friend to accompany employee on training trip An employee, who must undergo training outside the country, is allowed to be accompanied by a friend (who has no connection to the employer’s business) whose travel expenses (accommodation, airfare and meals) are paid by the employer. ...

30 October 2012 Ontario CTF Roundtable Q. 8, 2012-0462841C6- Ontario CTF – Q8 Residency of a Trust-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) trust residence following Fundy In response to a query on the Fundy Settlement case, CRA stated: Normally, residence of a trust is dependent upon residence of the trustee or trustees who can exercise management and control of the trust. ...