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2 November 2023 APFF Roundtable Q. 9, 2023-0982911C6- APFF- Congrès 2023- Table ronde sur la fiscalité-- summary under Personal-Use Property Summary Under Tax Topics- Income Tax Act- Section 54- Personal-Use Property bitcoin to be used for online purchases is not personal-use property Madame Y made a cash purchase of a bitcoin on a central exchange platform in order that she could ultimately pay for items online. Subsequently, in 2023, the exchange platform was the victim of fraud and Madame Y lost access to her bitcoin. ...

2 November 2023 APFF Roundtable Q. 9, 2023-0982911C6- APFF- Congrès 2023- Table ronde sur la fiscalité-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 54- Proceeds of Disposition- Paragraph (b) damages for loss of bitcoin from fraud would be compensation for property unlawfully taken Madame Y made a cash purchase of a bitcoin on a central exchange platform in order that she could ultimately pay for items online. Subsequently, in 2023, the exchange platform was the victim of fraud and Madame Y lost access to her bitcoin. ...

2 November 2023 APFF Roundtable Q. 9, 2023-0982911C6- APFF- Congrès 2023- Table ronde sur la fiscalité-- summary under Damages Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Loss v. ... Subsequently, in 2023, the exchange platform was the victim of fraud and Madame Y lost access to her bitcoin. ...

2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F- APFF- Congrès 2023- Table ronde sur la fiscalité-- summary under Subsection 152(8) Summary Under Tax Topics- 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 The Girardi decision (2014 QCCA 1922) stated, in connection with the Bankruptcy and Insolvency Act ("B.I.A. ...

2 November 2023 APFF Roundtable Q. 10, 2023-0993641C6- APFF- Congrès 2023 Q.10 disposition de cryptomonnaie-- summary under Disposition Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition there likely was a disposition of bitcoin on its transfer to a bitcoin platform In return for depositing the taxpayer’s bitcoins with a centralized cryptoasset exchange and lending platform, the latter offers the taxpayer a variable return of approximately 4% per annum, payable in bitcoin. ...

2 November 2023 APFF Roundtable Q. 10, 2023-0993641C6- APFF- Congrès 2023 Q.10 disposition de cryptomonnaie-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership bitcoin platform likely acquired ownership of bitcoin deposited with it In return for depositing the taxpayer’s bitcoins with a centralized bitcoin exchange and lending platform, the platform provides a variable return of approximately 4% per annum, payable in bitcoin. ...

2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F- APFF- Congrès 2023- Table ronde sur la fiscalité-- summary under Subsection 69(4) Summary Under Tax Topics- 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 Trustee of Girard, 2014 QCCA 1922, stated, in connection with the Bankruptcy and Insolvency Act ("B.I.A. ...

2 November 2023 APFF Roundtable Q. 12, 2023-0982931C6 F- APFF- Congrès 2023- Table ronde sur la fiscalité-- summary under Evidence Summary Under Tax Topics- General Concepts- Evidence documentation of a loss from the collapse of a crypto exchange After the taxpayer for a number of months had been trading on a daily basis in cryptocurrencies through an account held at a major cryptocurrency exchange platform, the platform went into bankruptcy on the discovery of fraud. ...

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-- summary under Qualifying Withdrawal Summary Under Tax Topics- 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 An individual and two unrelated individuals acquired a duplex in equal shares on December 10, 2023 and began living in one of the units as his principal place of residence on December 20, 2023, with the other unit being rented out. On November 2, 2023 (after their having entered into the purchase agreement) he withdrew funds from his FHSA. ...

3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 1, 2023-0976911C6 F- CELIAPP- Changement d'usage / FHSA- Change in use-- summary under Paragraph (d) Summary Under Tax Topics- 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 An individual purchased a single-family home in 2020 for rental to a third party, in May 2023 opened and contributed $8,000 to an FHSA and then, after the tenant vacated, moved into the home as his principal place of residence on November 1, 2023, so that there was a deemed disposition and reacquisition of the property pursuant to s. 45(1)(a) on that date. ...