Search - 教育部《义务教育课程方案（2023年版）》

2 November 2023- 11:46pm CRA releases the 2023 STEP Roundtable Email this Content CRA has released the official version of its answers at the 20 June 2023 STEP Roundtable. ... Topic Descriptor 20 June 2023 STEP Roundtable Q. 1, 2023-0961341C6- Personal-Use Property Income Tax Act- Section 54- Personal-Use Property separate testing of whether PUP of deceased is PUP of the estate Income Tax Act- Section 46- Subsection 46(1) personal-use property (PUP) of the deceased may not be PUP of the estate 20 June 2023 STEP Roundtable Q. 2, 2023-0961311C6- Worthless Property Income Tax Act- Section 152- Subsection 152(4.2) CRA may generally process capital losses that a deceased missed claiming if now claimed within the s. 152(4.2) 10-year period 20 June 2023 STEP Roundtable Q. 3, 2023-0968091C6- Trust Reporting – Definition of Money and Treatment of Dividend Receivable Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(b)- Subparagraph 150(1.2)(b)(i) gold or silver bar or coin would not qualify as “money”/ dividend receivable not included in “shares” 20 June 2023 STEP Roundtable Q. 4, 2023-0968111C6- Trust Reporting – Definition of Beneficiary Income Tax Regulations- Regulation 204.2- Subsection 204.2(1) "beneficiary" includes a contingent beneficiary 20 June 2023 STEP Roundtable Q. 5, 2023-0959801C6- Subsection 94(8) Recovery Limit Income Tax Act- Section 94- Subsection 94(3)- Paragraph 94(3)(d) illustration of the operation of the recovery limit rules on a resident beneficiary of a s. 94(3) trust that has unpaid Canadian taxes Income Tax Act- Section 94- Subsection 94(8) recovery limit formula operates beyond the taxation year in which unpaid taxes arose, irrespective of whether the trust continues to be a s. 94(3) trust 20 June 2023 STEP Roundtable Q. 6, 2023-0959571C6- Non-Resident Trust and Canadian Charity Income Tax Act- Section 94- Subsection 94(1)- Resident Beneficiary registered charity is not a resident beneficiary 20 June 2023 STEP Roundtable Q. 7, 2023-0959581C6- Deemed Resident Trust and the Resident Portion Income Tax Act- Section 95- Subsection 95(1)- Controlled Foreign Affiliate- Paragraph (b) NR corp wholly owned by s. 94(3) trust is CFA of the resident portion trust Income Tax Act- Section 94- Subsection 94(2)- Paragraph 94(2)(g)- Subparagraph 94(2)(g)(iv) application where a s. 94 trust lent to a resident beneficiary, and when loan repaid Income Tax Act- Section 94- Subsection 94(2)- Paragraph 94(2)(a) contribution to NR trust where beneficiary pays expenses of trust property Income Tax Act- Section 94- Subsection 94(1)- Resident Portion illustration of the resident portion rules for a s. 94 trust that inter alia has lent to a resident beneficiary or earns FAPI 20 June 2023 STEP Roundtable Q. 8, 2023-0961291C6- Trust and Related Income Tax Act- Section 251- Subsection 251(2)- Paragraph 251(2)(c)- Subparagraph 251(2)(c)(i) Consolidated Holding applied to s. 251(2)(c)(i) 20 June 2023 STEP Roundtable Q. 9, 2023-0961301C6- Paragraph 20(1)(ww) Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(ww) an s. 20(1)(ww) deduction is available for a TOSI taxable capital gain even where an offsetting allowable capital loss 20 June 2023 STEP Roundtable Q. 10, 2023-0965831C6- Non-Resident Corporations Owning Canadian Real Estate Income Tax Act- Section 214- Subsection 214(3)- Paragraph 214(3)(a) Pt. XIII tax is applicable where non-resident corporation makes a Canadian property available to its non-resident shareholder or family Income Tax Act- Section 15- Subsection 15(1) the benefit to a non-resident from personal use of a non-resident corporation’s Canadian cottage is reduced by an interest-free loan from the shareholder 20 June 2023 STEP Roundtable Q. 11, 2023-0971841C6- Non-Resident Owning Canadian Rental Real Estate Income Tax Act- Section 216- Subsection 216(1) policy for one-time acceptance of a late-filed s. 216 return 20 June 2023 STEP Roundtable Q. 12, 2023-0959591C6- Corporate Beneficiary and CDA Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (a)- Subparagraph (a)(i.1) no CDA addition if non-taxable half of capital gain is distributed to another beneficiary/ any CDA addition occurs at trust year end Income Tax Act- 101-110- Section 104- Subsection 104(21) s. 104(21) designation can be made re distributing the taxable half of a trust capital gain to a corporate beneficiary – who receives no CDA addition 20 June 2023 STEP Roundtable Q. 13, 2023-0966611C6- Trust Online Verification General Concepts- Audit and Assessment Procedure launch of My Trust Account 20 June 2023 STEP Roundtable Q. 14, 2023-0967371C6- s.70(6) & Application to Extend Income Tax Act- Section 70- Subsection 70(6) requesting an extension of the 36-month vesting period under s. 70(6) 20 June 2023 STEP Roundtable Q. 15, 2023-0963801C6- Interpretation of clause 110.6(1.3)(a)(ii)(A) Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1.3)- Paragraph 110.6(1.3)(a) s. 110.6(1.3)(a) can still be satisfied long after the farmer’s death 20 June 2023 STEP Roundtable Q. 16, 2023-0961321C6- Damages in Respect of Personal Injury or Death Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) a damages annuity to a child for a parent’s death would generally need to be under a structured settlement to be exempt Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(g.1) a damages annuity to a child for financial loss from a parent’s death would not be exempted under ss. 81(1)(g.1) and (g.2) 20 June 2023 STEP Roundtable Q. 17, 2023-0959621C6- Foreign Reporting, Estate, Income Tax Act- Section 233.6- Subsection 233.6(1) T1142 reporting requirements can arise once a foreign estate has been fully administered 20 June 2023 STEP Roundtable Q. 18, 2023-0966631C6- Foreign Tax Credit Verification and Delays Income Tax Act- Section 126- Subsection 126(1) CRA will accept alternatives to a foreign notice of assessment to evidence the foreign tax liability for foreign tax credit purposes ...

8 February 2024- 11:15pm CRA has released the final version of the 2 November 2023 APFF Roundtable Email this Content We have translated the complete 2 November 2023 APFF Roundtable as released by CRA yesterday in final form (which did not vary significantly from the preliminary version that was provided in November). ... Topic Descriptor 2 November 2023 APFF Roundtable Q. 1, 2023-0975421C6 F- Paragraph 25 of IT-293R (Archived) Income Tax Act- Section 9- Forgiveness of Debt reversal of CRA position that forgiveness of an old trade debt generally will be on capital account 2 November 2023 APFF Roundtable Q. 2, 2023-0982751C6- Meaning of purpose tests in paragraph 55(2.1) Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) the payment of a pre-closing dividend of significant excluded assets by the target to its parent likely would engage s. 55(2) where no safe income 2 November 2023 APFF Roundtable Q. 3, 2023-0984441C6 F- Qualified small business corporation share- meaning of "all or substantially all" and "asset" Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (d) a momentary right to discharge a dividend payable constitutes a non-active business asset for QSBCS purposes/ no rigid equating of "substantially all" with 90% 2 November 2023 APFF Roundtable Q. 4, 2023-0982781C6 F- Section 51 Share Exchange Income Tax Act- Section 51- Subsection 51(1) s. 51(1) is inapplicable to an exchange for identical shares 2 November 2023 APFF Roundtable Q. 5, 2023-0982821C6 F- Notion d’ « entreprise principale » aux fins du paragraphe 1100(12) R.I.R. ... Loss- Damages bitcoin loss from fraud might be capital loss, and timing of a loss could be governed by s. 44(2) 2 November 2023 APFF Roundtable Q. 10, 2023-0993641C6- APFF- Congrès 2023 Q.10 disposition de cryptomonnaie General Concepts- Ownership bitcoin platform likely acquired ownership of bitcoin deposited with it Income Tax Act- Section 248- Subsection 248(1)- Disposition there likely was a disposition of bitcoin on its transfer to a bitcoin platform 2 November 2023 APFF Roundtable Q. 11, 2023-0983621C6 F- Paragraph 12(1)(x) and Non-Refundable Tax Credit Income Tax Act- Section 53- Subsection 53(2)- Paragraph 53(2)(k) Quebec synergy tax credit is received on the due date for the related return, or when a carryforward or carryback request is made for it 2 November 2023 APFF Roundtable Q. 12, 2023-0982931C6 F- APFF- Congrès 2023- Table ronde sur la fiscalité General Concepts- Evidence documentation of a loss from the collapse of a crypto exchange 2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F- APFF- Congrès 2023- Table ronde sur la fiscalité Income Tax Act- Section 152- Subsection 152(8) stay of proceedings under the BIA is a procedural limitation that does not affect an assessment’s validity Other Legislation/Constitution- Federal- Bankruptcy and Insolvency Act- Section 69- Subsection 69(4) where a contested notice of assessment is subject to a stay, it generally must apply to the bankruptcy court for lifting the stay 2 November 2023 APFF Roundtable Q. 14, 2023-0982951C6 F- Article 56.4 L.I.R.- Clauses restrictives Income Tax Act- Section 56.4- Subsection 56.4(7)- Paragraph 56.4(7)(g) CRA will entertain applications for late s. 56.4(7)(g) (letter) elections 2 November 2023 APFF Roundtable Q. 15, 2023-0982901C6- Impact of the Collins Family Trust decision Income Tax Act- Section 152- Subsection 152(1) CRA lacks discretion to not apply the provisions of the ITA as judicially interpreted ...

4 December 2023- 11:13pm The CRA safe income policy changes announced on 28 November 2023 are effective for taxation years commencing after that date Email this Content Today, the Canadian Tax Foundation posted the following message on CRA’s behalf regarding CRA presentation on “ S. 55(2) and Safe Income- Where Are We Now? ”: Pursuant to our presentation on Safe Income at the 2023 Annual Conference on November 28, 2023, all announcements that constitute a change in position will apply prospectively to calculations of safe income for taxation years beginning after November 28, 2023. ... Summary of 4 December 2023 Canadian Tax Foundation Event Announcement under s. 55(2.1)(c). ...

2 August 2023- 11:18pm CRA releases the official 2023 IFA Roundtable Email this Content CRA has released the final version of the May 17, 2023 IFA Roundtable. ... Topic Descriptor 17 May 2023 IFA Roundtable Q. 1, 2023-0964391C6- stock based compensation and transfer pricing Income Tax Act- Section 7- Subsection 7(3)- Paragraph 7(3)(b) s. 7(3)(b) non-deduction or s. 112(1)(e) deductibility could apply to cross-border stock option recharges of non-resident parent Income Tax Act- Section 247- New- Subsection 247(2) stock-compensation expenses may be relevant to pricing cross-border services charges even where s. 7(3)(b) prohibits their deduction 17 May 2023 IFA Roundtable Q. 2, 2023-0964301C6- Ukraine Russia FAs and Tax Reporting Income Tax Act- Section 233.5 failure to file complete information for affiliate in war-torn country Income Tax Act- Section 220- Subsection 220(2.1) potential relief from return-filing requirements re FA in war-torn country 17 May 2023 IFA Roundtable Q. 3, 2023-0964551C6- T1134 Supplement Income Tax Act- Section 233.5 T1134 should be timely-filed with missing information noted Income Tax Act- Section 90- Subsection 90(2) a pro rata distribution by an LLLP to its members is a dividend 17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Treaties- Income Tax Conventions- Article 29 Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion 17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6- Remote Work Arrangements Income Tax Act- Section 253- Paragraph 253(b) s. 253(b) does not extend to “invitation to treat” or advertisement Income Tax Act- Section 253- Paragraph 253(a) product development from Canadian home office might engage s. 253(a) Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) whether Canadian home offices of US employees can give rise to it carrying on business in Canada Treaties- Income Tax Conventions- Article 5 whether employee’s home office can constitute a PE of US employer 17 May 2023 IFA Roundtable Q. 6, 2023-0964351C6- Application of the Canada-US Treaty Treaties- Income Tax Conventions- Article 4 Treaty benefits could be created for a s. 216 structure by creating partnerships for US purposes 15 September 2020 IFA Roundtable Q. 7, 2020-0853571C6- Regulation 5901(2)(b) Pre-Acquisition Surplus Election Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b)- Subparagraph 5901(2)(b)(ii) Reg. 5901(2)(b)(ii)(A) does not taint a siloed dividend paid by FA to Canco1 even though another Canco holds other FA shares through an LP 17 May 2023 IFA Roundtable Q. 7, 2023-0964521C6- Application of Article 10, Canada-Hong Kong Treaties- Multilateral Instrument- Article 7- Article 7(1) the PPT object and purpose test is met where individuals in a Treaty country transfer their Canco shares to a Treaty-resident Holdco to reduce dividend withholding Treaties- Income Tax Conventions- Article 10 violating main purpose test in HK Treaty increases dividend rate/ PPT object and purpose test not violated by using personal holding company in same jurisdiction 17 May 2023 IFA Roundtable Q. 8, 2023-0964561C6- Tax-free Surplus Balance and Paragraph 88(1)(d) Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(d)- Subparagraph 88(1)(d)(ii)- Variable C surplus computation not required in typical bump and run transaction Income Tax Regulations- Regulation 5905- Subsection 5905(5.4) no surplus calculations needed where FA of Canadian target is acquired by Forco through a Cdn. ...

14 February 2024- 11:21pm CRA has released the final version of the 3 November 2023 APFF Financial Strategies and Instruments Roundtable Email this Content We have translated the complete 3 November 2023 APFF Financial Strategies and Instruments Roundtable. ... Topic Descriptor 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 1, 2023-0976911C6 F- CELIAPP- Changement d'usage / FHSA- Change in use Income Tax Act- Section 146.6- Subsection 146.6(1)- Qualifying Withdrawal- Paragraph (d) a recent change of a home from rental to principal-residence use cannot ground an FHSA withdrawal 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 2, 2023-0978631C6 F- CELIAPP- Autoconstruction d'une habitation- FHSA- Self-construction Income Tax Act- Section 146.6- Subsection 146.6(1)- Qualifying Withdrawal- Paragraph (c) written agreement for construction before October 1 could be satisfied with agreements with trades by self-constructing individual Income Tax Act- Section 146.6- Subsection 146.6(1)- Qualifying Withdrawal- Paragraph (a) acquisition of home is when it becomes habitable 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 3, 2023-0976921C6 F- CELIAPP- Acquisition d'une quote-part d'une habitation admissible / FHSA- Acquisition of a share of a qualifying home General Concepts- Ownership reference to acquiring a qualifying home includes acquiring a co-ownership interest Income Tax Act- Section 146.6- Subsection 146.6(1)- Qualifying Withdrawal a qualifying withdrawal from an FHSA can fund the purchase of a co-ownership interest in a qualifying home 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 4, 2023-0990531C6 F- Life insurance policy transfer Income Tax Act- 101-110- Section 106- Subsection 106(3) s. 106(3) could apply to a distribution of a dividend in kind Income Tax Act- 101-110- Section 107- Subsection 107(2) s. 107(2) inapplicable to distribution in satisfaction of a trust debt owing to the beneficiary Income Tax Act- Section 148- Subsection 148(7) a trust distribution of a life insurance policy to a beneficiary was made for FMV consideration equal to the part of the beneficiary’s capital or income interest that is satisfied 2 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 5, 2023-0978561C6 F- Partnership – distribution of a life insurance police Income Tax Act- Section 248- Subsection 248(35) holding of policy by partnership prior to its distribution to partner does not count towards the latter’s holding period Income Tax Act- Section 148- Subsection 148(7) s. 98(2) generally prevails over s. 148(7) Income Tax Act- Section 98- Subsection 98(2) disposition of distributed life insurance policy at FMV pursuant to s. 98(2), rather than s. 148(7) applying 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 6, 2023-0994241C6 F- Consequences of Transfer of DSUs to a corporation Income Tax Act- Section 54- Capital Property deferred share units were not capital property Income Tax Act- Section 85- Subsection 85(1.1) DSU rights are not eligible property and not capital property Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement transfer of DSU to corporation would cause it to cease to qualify, perhaps retroactively 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 7, 2023-0994231C6 F- Additional reporting- trusts subject to exception Income Tax Regulations- Regulation 204.2- Subsection 204.2(1) trusts not coming within the preamble to ITA s. 150(1.2) must still provide the additional Reg. 204.2(1) information if not excepted under ss. 150(1.2)(a) to (o) 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 8, 2023-0976901C6 F- RPP survivor benefit flowing through a GRE Income Tax Act- Section 60- Paragraph 60(j) flow-through of pension benefit by estate to surviving spouse through cash and note issuance/ no FHSA deduction for s. 104(27) amount Income Tax Act- 101-110- Section 104- Subsection 104(24) income can be distributed to estate beneficiary by issuing a demand note to her Income Tax Act- 101-110- Section 104- Subsection 104(27) full flow-through of a pension benefit received by the estate to the surviving spouse for s. 60(j) purposes by the estate issuing her a note 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 9, 2023-0976941C6- Withholding on registered plans Treaties- Income Tax Conventions- Article 18 RRSP/ RRIF payments are “pensions” under Art. ... Convention applies to TFSA and RDSP trusts 3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 10, 2023-0978651C6- Exchange rate for a stripped interest coupon Income Tax Act- Section 261- Subsection 261(2)- Paragraph 261(2)(b) deemed interest on an FX-denominated stripped coupon should be translated on a daily basis ...

30 March 2023- 10:46pm CRA announces that UHTA returns will not attract late-filing penalties or interest if received by October 31, 2023 Email this Content CRA has announced: The application of penalties and interest under the UHTA for the 2022 calendar year will be waived for any late-filed underused housing tax (UHT) return and for any late-paid UHT payable, provided the return is filed or the UHT is paid by October 31, 2023. This transitional relief means that although the deadline for filing the UHT return and paying the UHT payable is still April 30, 2023, no penalties or interest will be applied for UHT returns and payments that the CRA receives before November 1, 2023. ... Summary of 27 March 2023 CRA News Release, Underused Housing Tax penalties and interest waived, under UHTA, s. 48(1). ...

14 April 2023- 10:09am GST/HST Severed Letters December 2023 Email this Content This morning's release of two severed letters from the Excise and GST/HST Rulings Directorate (identified by them as their January 2023 release) is now available for your viewing. ...

28 June 2023- 1:48pm GST/HST Severed Letters February 2023 Email this Content This morning's release of 10 severed letters from the Excise and GST/HST Rulings Directorate (identified by them as their February 2023 release) is now available for your viewing. ...

12 July 2023- 11:28am GST/HST Severed Letters March/April 2023 Email this Content This morning's release of five severed letters from the Excise and GST/HST Rulings Directorate (identified by them as their March and April 2023 release) is now available for your viewing. ...

21 July 2023- 6:49pm GST/HST Severed Letters May 2023 Email this Content This morning's release of 11 severed letters from the Excise and GST/HST Rulings Directorate (identified by them as their May 2023 release) is now available for your viewing. ...