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20 June 2023 STEP Roundtable Q. 14, 2023-0967371C6- s.70(6) & Application to Extend Principal Issues: (A) What is the process for making a written application to extend the 36 month period for property to become vested indefeasibly with the surviving spouse or common-law partner, or a testamentary spousal or common-law partner trust? ... (B) A written application should include details that provide the director of the legal representative’s tax services office with a clear picture of the reason for the extension request. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 14. ... One condition is that the deceased’s property vests indefeasibly with the surviving spouse or common-law partner, or a testamentary spousal or common-law partner trust: “…if it can be shown, within the period ending 36 months after the death of the taxpayer or, where written application therefore has been made to the Minister by the taxpayer's legal representative within that period, within such longer period as the Minister considers reasonable in the circumstances, that the property has become vested indefeasibly in the spouse or common-law partner or trust, as the case may be…” The T4011 Guide – Preparing Returns for Deceased Persons notes that if the legal representative needs more time to meet this condition, they can make a written request to the director at their tax services office before the end of the 36 month period. ...

Opco crée Filiaco dont elle souscrit à 100% des actions pour une somme de 200 000 $. ... X détient dans le capital-actions de Opco pour 200 000 $ payés comptant. ... X s'effectuerait pour une contrepartie correspondant à la juste valeur marchande desdites actions au moment de la disposition, et que Opco serait une " société privée " au sens de la définition prévue au paragraphe 89(1) L.I.R. ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12 Unedited CRA Tags Article 10, 11 & 12 of Canada's Tax Conventions Principal Issues: 2009 IFA Conference Question #1- Beneficial Owner Position: See comments Reasons: See comments 2009 IFA Conference, May 21, 2009 Canada Revenue Agency Round Table Question 1- Beneficial Ownership Given the FCA decision in Prevost Car, what is the CRA's current view in regard to beneficial ownership as it relates to back-to-back dividends, interest and royalties? ...

16 June 2014 STEP Roundtable, 2014-0523091C6- STEP CRA Roundtable – June 2014 CRA Tags 248(8) 252(3) 70(6.2) 70(6) 248(1) 70(5) Principal Issues: Can the rollover provisions of subsection 70(6) apply to a transfer of property to a taxpayer's spouse and transfer of another property to a common-law partner? ... STEP CRA Roundtable – June 2014 QUESTION 1. Transfer to Spouse and Common-Law Partner A rollover is available under subsection 70(6) where property is left by a taxpayer resident in Canada to a taxpayer's spouse or common-law partner who is resident in Canada immediately before the taxpayer's death. ...

12 June 2012 June STEP Roundtable, 2012-0442681C6- STEP CRA Roundtable – June 2012- Question 2 CRA Tags 86 160(1) 160(4) 85 Principal Issues: Would 160(1) or 160(4) apply in the case of a butterfly reorganization? ... STEP CRA Roundtable – June 2012 QUESTION 2 Section 160 provides for joint and several liability between a transferor and a non-arm's length transferee where a transfer has occurred at less than fair market value. ...

28 November 2010 Roundtable, 2011-0424761C6- CTF 2010 Q&A #22- ELHTs & HWTs CRA Tags 6(1) 144.1 Principal Issues: Interaction of new ELHT regime with existing HWT regime Position: Both will exist 2010 CTF – November 28, 2010 Employee Life and Health Trusts Question 22 On August 27, 2010, the Department of Finance released revised legislative proposals to accommodate new employee benefit arrangements called employee life and health trusts (ELHTs). ...

3 May 1994 Roundtable Q. 1, 9411620- SAFE INCOME & ALBERTA ROYALTY TAX CREDITS Unedited CRA Tags 55(2) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ... Principal Issues:- Alberta Royalty Tax Credits & Safe Income Position TAKEN:- treated like government assistence for purposes of safe income Reasons FOR POSITION TAKEN:- Consistent with position taken in 91 paper presented by M. ...

26 November 2013 Annual CTF Roundtable, 2013-0509061C6- Part XIII Tax & Standard Convertible Debentures CRA Tags 212(3) 212(1)(b) 214(7) Principal Issues: 1. ... & 2. Generally no. Reasons: 1. & 2. See below. NOVEMBER 26, 2013 ROUND TABLE DISCUSSION 2013 CTF 65th ANNUAL CONFERENCE Part XIII Tax in Respect of Convertible Debentures The Income Tax Rulings Directorate ("ITRD") recently issued a favourable ruling (document 2011-0418721R3, "Letter") to the effect that paragraph 212(1)(b) of the ITA did not apply to regular periodic interest payments on certain convertible notes issued to non-residents, provided that the public corporation deals at arm's length with the non-resident at the time of the payments. ...

20 June 2023 STEP Roundtable Q. 3, 2023-0968091C6- Trust Reporting – Definition of Money and Treatment of Dividend Receivable Unedited CRA Tags 150(1); 150(1.1); 150(1.2)(b); ITR 204.2 Principal Issues: 1) Whether settlement items such as collectible gold/silver coins and bars would be considered “money” for the purposes of paragraph 150(1.2)(b)? ... Reasons: 1) Ordinary meaning of the term "money". 2) The law. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 3. Trust Reporting – Definition of Money and Treatment of Dividend Receivable Pursuant to paragraph 150(1.2)(b) of the Income Tax Act (Canada) (the “Act”) (footnote 1), subsection 150(1.1) can apply to a trust for a particular tax year where, the trust holds assets with a fair market value that does not exceed $50,000 throughout the year, if the only assets held by the trust throughout the year are one or more of (i) money, (ii) a debt obligation described in paragraph (a) of the definition fully exempt interest in subsection 212(3), (iii) a share, debt obligation or right listed on a designated stock exchange, (iv) a share of the capital stock of a mutual fund corporation, (v) a unit of a mutual fund trust (vi) an interest in a related segregated fund trust (within the meaning assigned by paragraph 138.? ...

8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6- Qualifying person & multiple shares Unedited CRA Tags Subparagraph 2(c) of Article XXIX-A of the Canada-U.S. ... Reg. § 1.884-5(d)(4)(i)(B). Under the regulation, a class of shares is considered to be "regularly traded" if (i) trades of the class of shares are made in more than de minimis quantities on at least 60 days during the taxable year (hereafter the "de minimis test"), and (ii) the aggregate number of shares in the class traded during the year is at least 10 percent of the average number of outstanding shares during the year (hereafter the "10-percent test"). ...