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LLPs & LLLPs Classification CRA Tags 248(1) "corporation" Principal Issues: Whether LLPs and LLLPs governed by the laws of Florida or Delaware would generally be treated as corporations for the purposes of the Act? ... STEP CRA Roundtable – June 10, 2016 Question 8 – Characterization of LLPs and LLLPs What is the status of the CRA’s review of the characterization for Canadian tax purposes of U.S. ... The main factors we considered in our analysis of these entities are the existence of a separate legal personality that is recognized under the law of the relevant foreign jurisdiction – meaning the full legal capacity to acquire and own property, to sue and be sued, to carry on their own activities and to incur liabilities of their own – and the extensive limitation of liability afforded to all of their members. ...

Income Inclusion – Overview Pursuant to the Act, a taxpayer, who is resident of Canada, is subject to income tax on all items of revenue received from all sources inside or outside of Canada. ... CCA – Overview A taxpayer may claim CCA only on property described in Schedule II of the Regulations that was acquired for the purpose of earning income. ... Specified Energy Property Rules – Overview The specified energy property rules contained in subsections 1100(24) to (29) of the Regulations limit the amount of CCA that may be claimed on property that is “specified energy property.” ...

12 July 2013 External T.I. 2011-0415911E5- FA held through partnership-– 95(2)(m) & 95(2)(y) CRA Tags 95(2)(m) 95(2)(y) Principal Issues: For the purposes of applying paragraph 95(2)(a) in determining whether a taxable Canadian corporation that is a member of a partnership has FAPI, does paragraph 95(2)(y) apply to prevent the partnership from having a qualifying interest in a foreign affiliate the shares of which are owned through the partnership? ... XXXXXXXXXX 2011-041591 Yannick Roulier July 12, 2013 Dear XXXXXXXXXX: Re: Foreign affiliate held through a partnership –- paragraphs 95(2)(m) & 95(2)(y) This is further to a letter from XXXXXXXXXX dated July 26, 2011, requesting our comments regarding the application of paragraphs 95(2)(m) and (y) of the Income Tax Act in a situation where a foreign affiliate is held through a partnership. ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference CRA Tags 104(4)(a) 70(5) Principal Issues: Estate Freeze Valuation of Shares. ... Reasons: See below. 2010 CTF Conference – November 28, 2010 Value of Vote-Only Shares – Question 17 Question: At the 2009 British Columbia Tax Conference the CRA stated that in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of the estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, the CRA generally accepts not to take into account any premium that could be attributable to such shares for the purposes of subsection 70(5). ... Response — The CRA does not have an established position on valuing different types of property. ...

28 September 2023 CLHIA Roundtable Q. 4, 2023-0974191C6- IPPs & Investments Unedited CRA Tags Subparagraph 56(1)(a)(i), subsections 147.1(5), 147.2(2) & 147.3(7), Reg. 8502(h), 8514(1)(b) and (c) Principal Issues: 1. ... CLHIA CRA Roundtable September 28, 2023 Question 4 – IPPs & Investments Question 4 a) Paragraphs 8514(1)(b) and (c) of the Income Tax Regulations (the “Regulations”) contain wording that could be interpreted as prohibiting a registered pension plan (“RPP”) from holding a life insurance policy based on the life of a plan member. ...

9 January 2019 External T.I. 2018-0753891E5- METC – list of fertility related procedures Unedited CRA Tags ITA: 118.2, 118.2(2)(a), (n), and (o), and 118.2(2.2)) Principal Issues: Whether there is a list of fertility-related procedures that are considered to be eligible medical expenses for the purposes of the METC. ... Drugs – Paragraph 118.2(2)(n) Paragraph 118.2(2)(n) of the Act allows as an eligible medical expense amounts paid for drugs, medicaments or other preparations or substances if certain conditions are met. ... More information regarding subsection 118.2(2.2) is contained on CRA webpage Medical Expenses Tax credit (METC) – Reproductive Technologies. ...

14 August 2014 Internal T.I. 2013-0506691I7- Capital Losses- Health & Welfare Trusts CRA Tags 3(b) 127.52(1) 111(1.1)(a) Principal Issues: Whether a HWT is permitted to deduct net capital losses when computing taxable income under Division C and/or adjusted taxable income under Division E.1? ... August 14, 2014 Taxpayer Services Directorate Income Tax Rulings Directorate Taxpayer Services and Debt Business and Employment Division Management Branch Tom Baltkois Attention: Yves Thivierge 2013-050669 Capital Losses – Health & Welfare Trusts We are writing in response to your email dated September 27, 2013, in which you requested clarification as to whether health and welfare trusts ("HWTs") are permitted to incur capital losses and deduct net capital losses when computing taxable income under Division C and/or adjusted taxable income under Division E.1 of the Income Tax Act (the "Act"). ...

14 September 2017 Roundtable, 2017-0703921C6- 2017 CPA Alberta Q25: Estates – Income Paid or Payable Unedited CRA Tags 104(13), 104(24), 104(6) Principal Issues: 1. ... Question of fact and law. 2017 CPA Alberta Roundtable Question 25- Estates – Income Paid or Payable An individual’s will commonly provides for his or her estate, or the residue thereof, to pass to one or more beneficiaries in fixed proportions. ... Response CRA Response (a) – (c) The CRA has previously noted that pursuant to subsection 104(6) there may be deducted in computing the income of an estate or trust for a taxation year, such amount as the estate or trust claims that would be its income for the year as became payable in the year to a beneficiary. ...

5 December 2017 Roundtable, 2017-0734841C6- 2017 TEI – Question E3 Unedited CRA Tags 87(8.4), (8.5), 116 Principal Issues: Joint election under proposed paragraph 87(8.4)(e) and its interaction with section 116. ... TEI – CRA Liaison Meeting – December 5, 2017 Question E3- Section 116 procedures for tax-deferred dispositions of taxable Canadian property on foreign mergers Background On September 16, 2016, the Department of Finance released draft legislation (proposed subsections 87(8.4) and (8.5)) to provide a mechanism for deferral of recognition of gains and losses from dispositions of shares of Canadian-resident corporations caused by certain foreign mergers, provided such shares are “taxable Canadian property” (“TCP”) and do not constitute “treaty-protected property.” ...

15 June 2022 STEP Roundtable Q. 13, 2022-0929381C6- 164(6) – Amending Deceased’s Final T1 Return Unedited CRA Tags 164(3)(d); 164(5)(d),(i),(j) and (k); 164(6) Principal Issues: 1. ... Paragraphs 164(5)(d), (i), (j) and (k) apply for the purpose of the interest refund rules in subsection 164(3) and deem the overpayment to have arisen on the day that is 30 days after the latest of these three days. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 13. Subsection 164(6) – Amending Deceased’s Final T1 Return Subsection 164(6) of the Act (footnote 1) allows capital losses of a graduated rate estate in its first taxation year to be considered capital losses of the deceased, where all required conditions are met. ...