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This is claimed by filing form T3A — Request for Loss Carryback by a Trust. ... Official Response 26 November 2020 STEP Roundtable Q. 13, 2020-0847201C6- GRE & section 216 election Q.14 Adjusted Aggregate Investment Income Subsection 125(5.2) is an anti-avoidance rule which may apply if a particular corporation transfers “property” at any time, either directly or indirectly to another corporation which is related to but not associated with the particular corporation, in circumstances where one of the reasons the loan or transfer was made was to reduce the “adjusted aggregate investment income” (“AAII”) of the particular corporation. ... Because of these strict requirements, practitioners have for years been concerned — and experienced the results of such concerns — that many estates may not be eligible for such planning because of the tight timelines and requirements for an actual disposition. ...

Is it just the taxpayer – is the taxpayer the unit of risk, so that taxpayers are either risky or not risky? ... Canadian law gives the Minister broad power to compel the production of information – the word “any” is there in the Act – but of course judges have imposed a reasonableness test. ... We are working around in the T1 space – letting taxpayers “load in” their T4. ...

Codifying those principles can be tricky – I understand why the drafters went with “appropriate in the circumstances.” ... The Communiqué puts some conditions around it – reasonableness and restraint. ... Not every file will be resolved this way – one of our criteria is that the adjustment in question must be at least $100 million. ...

Element C in the s. 6(2) formula appears to contemplate that the cost of the automobile to a person (Holdco) related to the employer is to be taken into account – but 2014-0529991E5 appears to indicate that the leasing cost to Opco should instead be used. ... The formula in subsection 6(2) is worded as follows: A/B × [2% × (C × D) + 2/3 × (E – F)] Element C of this formula represents the cost of the automobile to the employer or to a person related to the employer if either of them owns the vehicle at any time in the year. ... Official response 6 October 2017 APFF Roundtable Q. 14, 2017-0720321C6 F- GAAR & 21-year rule planning Q.15 Step-up of goodwill on loss restriction event The sole asset of a corporation sold to a 3 rd party is goodwill with a fair market value of $200,000. ...

Brault: The CRA is currently part of three ICAP 2.0 risk assessments – one is complete and two are still in progress. ... Brault: The document is in final stages of approval – it should hopefully be ready in weeks rather than months. ... There is quite a number of applications – over 2 million if you look period-by-period – so that 100% coverage is infeasible. ...

At the 2015 STEP – CRA Roundtable, CRA stated that an individual can only have one estate. ... Anyone wanting to access that Q & A, can go to the CRA website and use the search tool to enter in “graduated rate estate”- and the Q & A will be the first hit for the search. ... Further, the settlor / grantor can exercise his / her power to revoke the trust at any time. ...

Of course, the screening process technically begins even earlier, with the audit team’s decision on whether to refer the matter to Headquarters in the first place, so that it is possible that some things get missed – which is to say that, from a taxpayer perspective, things could certainly be worse! ... We had a new communique out to our auditors, which should be on our website fairly soon, that talks about what we call audit agreements – that’s a settlement at audit stage – what’s involved and when we engage that process. ... Written communication is not an effective way to address certain emergent Questions – such as whether particular words or statements under consideration are being taken out of context. ...

Process for inital contact – do requests go to taxpayer, representatve, or both? ... Process for initial contact – do requests go to taxpayer, representative, or both? ...

In the situation described above, will CRA consider that UKco has a permanent establishment in Canada under Article 5 of the Canada – U.K. ... ASIC Miners ASIC miners, on the other hand, are designed and optimised to perform a single task – mine crypto-assets. ... (iii) Part II Section 3A – Surplus Accounts – 4. Upstream Loan Rules (Table) Column 2 of the Table requires reporting entities to identify if a specified debtor (as defined in subsection 90(15)) owes an amount to the foreign affiliate (or a partnership of which the foreign affiliate was a member) at any time during the reporting period. ...

Such assets might be disposed of before the acquistion – or immediately after the acquisition. ... XXVI and Annex A, there were (per Susan) very few cases of ultimate double taxation, the presence of arbitration has speeded (by approximately 1/3) the resolution of Mutual Agreement Procedure cases due to the incentive for the two competent authorities to grapple with the more difficult issues on a more expeditious basis – and (per Susan) the resulting habit of greater efficiency also has speeded the handling of MAP files for third countries. The dialogue in a MAP case will be continued for so long as it can be carried forward (per Patricia) – and even if arbitration has commenced, the two authorities will continue to try to resolve the dispute consensually. ...