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Conference summary
2 November 2023 APFF Roundtable Q. 9, 2023-0982911C6 - APFF - Congrès 2023 - Table ronde sur la fiscalité -- summary under Paragraph (b)
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. ...
Conference summary
2 November 2023 APFF Roundtable Q. 9, 2023-0982911C6 - APFF - Congrès 2023 - Table ronde sur la fiscalité -- summary under Damages
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. ...
Conference summary
2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F - APFF - Congrès 2023 - Table ronde sur la fiscalité -- summary under Subsection 152(8)
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. ...
Conference summary
2 November 2023 APFF Roundtable Q. 10, 2023-0993641C6 - APFF - Congrès 2023 Q.10 disposition de cryptomonnaie -- summary under Disposition
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. ...
Conference summary
2 November 2023 APFF Roundtable Q. 10, 2023-0993641C6 - APFF - Congrès 2023 Q.10 disposition de cryptomonnaie -- summary under Ownership
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. ...
Conference summary
2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F - APFF - Congrès 2023 - Table ronde sur la fiscalité -- summary under Subsection 69(4)
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. ...
Conference summary
2 November 2023 APFF Roundtable Q. 12, 2023-0982931C6 F - APFF - Congrès 2023 - Table ronde sur la fiscalité -- summary under Evidence
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. ...
Article Summary
Joint Committee, "Summary of Comments and Recommendations Provided to the Department of Finance on the General Anti-Avoidance Rule Proposals Released on March 28, 2023", Joint Committee Submission dated 7 June 2023 -- summary under Subsection 237.3(12.1)
Joint Committee, "Summary of Comments and Recommendations Provided to the Department of Finance on the General Anti-Avoidance Rule Proposals Released on March 28, 2023", Joint Committee Submission dated 7 June 2023-- summary under Subsection 237.3(12.1) Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(12.1) Without prejudice disclosures There should be a s. 245 rule stating that a disclosure filed under proposed s. 237.3(12.1) cannot be used as a factor in any way when determining whether GAAR applies. ...
Article Summary
Joint Committee, "Summary of Comments and Recommendations Provided to the Department of Finance on the General Anti-Avoidance Rule Proposals Released on March 28, 2023", Joint Committee Submission dated 7 June 2023 -- summary under Subsection 245(4.1)
Joint Committee, "Summary of Comments and Recommendations Provided to the Department of Finance on the General Anti-Avoidance Rule Proposals Released on March 28, 2023", Joint Committee Submission dated 7 June 2023-- summary under Subsection 245(4.1) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4.1) Need for further examples In addition to the TFSA example provided by Finance, other examples of transactions without a high level of economic substance are loss consolidation transactions and post-mortem planning. ...
Article Summary
Joint Committee, "Summary of Comments and Recommendations Provided to the Department of Finance on the General Anti-Avoidance Rule Proposals Released on March 28, 2023", Joint Committee Submission dated 7 June 2023 -- summary under Subsection 245(5.1)
Joint Committee, "Summary of Comments and Recommendations Provided to the Department of Finance on the General Anti-Avoidance Rule Proposals Released on March 28, 2023", Joint Committee Submission dated 7 June 2023-- summary under Subsection 245(5.1) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(5.1) Effective date The GAAR proposals should apply prospectively so that they would not apply to a series of transactions that commenced before the effective date. ...