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15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6- 78(1)(b)(ii) deemed loan & thin capitalization-- summary under Subparagraph (a)(ii) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(5)- Outstanding Debts to Specified Non-Residents- Paragraph (a)- Subparagraph (a)(ii) unpaid simple interest that is deemed to be a loan by s. 78(1)(b)(ii) generally is not outstanding debts to specified non-residents Assuming compound interest does not accrue on unpaid simple interest owing by a Canadian corporation to a non-resident creditor for which an agreement under s. 78(1)(b)(ii) was made so as to deem the amount of that simple interest to be a loan, is that deemed loan considered to be included in “outstanding debts to specified non-residents” as defined in s. 18(5)? ...

14 April 2020 APFF Roundtable Q. 5, 2020-0845431C6 F- Avantage imposable- télétravail / Taxable benefit-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) employer reimbursement of up to $500 for the cost of a telework computer is non-taxable during COVID-19 In the context of a teleconference on COVID-19, CRA confirmed that payments made by an employer to its employees, to enable them to equip themselves to telework, would be taxable to the employees, unless the payment was conditional on an invoice being submitted by the employee, as to which CRA stated: In principle, an employee receives a taxable benefit when the employee’s employer reimburses a personal expense to acquire telework equipment. ...

8 July 2020 CALU Roundtable Q. 3, 2020-0842151C6- Insurance Proceeds & CDA-- summary under Subparagraph (d)(ii) Summary Under Tax Topics- Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (d)- Subparagraph (d)(ii) the two components received under a “face amount plus fund value” universal life policy are included in computing the corporate policy owner’s CDA A universal life (UL) policy (referred to as “face amount plus fund value”) purchased by Opco as an exempt policy upon the life of its shareholder provides for the payment of a death benefit equal to the fund value of the policy (being the accumulated balance of the investment accounts within the policy at the time of the death of the life insured) plus the face amount. ...

26 November 2020 STEP Roundtable Q. 13, 2020-0847201C6- GRE & section 216 election-- summary under Graduated Rate Estate Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Graduated Rate Estate non-resident estate can be GRE and file s. 216 returns On the death of a non-resident individual, who had been filing T1 returns pursuant to the s. 216 rules regarding a Canadian rental property, that property was acquired by her non-resident estate at FMV, then was distributed to her two non-resident children (Y and Z- the residuary beneficiaries) as equal co-owners. ...

26 November 2020 STEP Roundtable Q. 13, 2020-0847201C6- GRE & section 216 election-- summary under Subsection 107(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(2) s. 107(2) applicable to distribution by NR estate of Canadian rental property NR residuary beneficiaries On the death of a non-resident individual, who had been filing T1 returns pursuant to the s. 216 rules regarding a Canadian rental property, that property was acquired by her non-resident estate at FMV, then was distributed to her two non-resident children (Y and Z- the residuary beneficiaries) as equal co-owners. ...

7 October 2020 APFF Roundtable Q. 8, 2020-0852201C6 F- Acheminement du CDC / CDA Streaming-- summary under Subsection 83(2.1) Summary Under Tax Topics- Income Tax Act- Section 83- Subsection 83(2.1) s. 83(2.1) does not generally apply to the streaming of capital dividends to one of the original shareholders ACO (a CCPC) has three corporate shareholders, each holding 10 Class A common shares in its capital: BCO (exempt under s. 149(1)); CCO (a non-resident); and DCO (a taxable CCPC). ...

23 March 2021 TEI Roundtable, 2021-0879631C6- CERS- Net Leases, Qualifying Revenue & Deadlines-- summary under Subclause (a)(i)(C)(II) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Qualifying Rent Expense- Variable A- Paragraph (a)- Subparagraph (a)(i)- Clause (a)(i)(C)- Subclause (a)(i)(C)(II) requirement for utilities to be paid under the lease can permit payments to 3rd party In responding to questions as to whether utilities paid by a tenant can qualify as qualifying rent expenses and be claimed under the Canada emergency rent subsidy (“CERS”), CRA indicated: If a tenant pays utilities in addition to rent under a lease that is not a net lease, those amounts do not qualify. ...

23 March 2021 TEI Roundtable, 2021-0879631C6- CERS- Net Leases, Qualifying Revenue & Deadlines-- summary under Rent Subsidy Percentage Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Rent Subsidy Percentage CERS/CEWS similarity in computing revenue reduction Does an eligible entity compute its qualifying revenue using the same approaches and elections for both the CEWS and the CERS for a particular qualifying period? ...

5 May 2021 IFA Roundtable Q. 3, 2021-0888281C6- IFA 2021 Q.3: 247(3)- C$5 M Threshold & 261(5)-- summary under Subparagraph 247(3)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 247- New- Subsection 247(3)- Paragraph 247(3)(b)- Subparagraph 247(3)(b)(ii) C$5M threshold is to be converted on the 1st day of the functional currency company’s taxation year in which the adjustments are made A Canadian corporation (“Canco”) with an elected functional currency is subject to transfer pricing income adjustments respecting a functional currency year. ...

15 June 2022 STEP Roundtable Q. 13, 2022-0929381C6- 164(6) – Amending Deceased’s Final T1 Return-- summary under Subsection 164(3) Summary Under Tax Topics- Income Tax Act- Section 164- Subsection 164(3) commencement of refund interest where loss transferred from GRE to terminal return If an election under s. 164(6) results in a refund, when does interest begin to accrue thereon? ...