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15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency-- summary under Paragraph 261(5)(a) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(5)- Paragraph 261(5)(a) different currency reporting of s. 85(1) rollover where one party has elected a functional currency CRA indicated that where the parties to a s. 85 rollover transaction have different tax reporting currencies (as defined in s. 261(1)), it would require that two separate forms T2057 be filed. ...

16 June 2014 STEP Roundtable, 2014-0526591C6- STEP CRA Roundtable – June 2014 – Question 9-- summary under Subsection 156(1) Summary Under Tax Topics- Income Tax Act- Section 156- Subsection 156(1) relief for interest and penalties on deficient inter vivos trust instalments Does CRA assess instalment interest and penalties where an inter vivos trust has not made instalment payments required under s. 156? ...

10 June 2019 Internal T.I. 2019-0796221I7 F- Qualification d’un véhicule à titre de « voiture de tourisme »-- summary under Automobile Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Automobile a passenger vehicle ceases to qualify as such when it commences to be used as a taxi given the s. 13(7)(b) deemed acquisition When asked as to the qualification of a vehicle as a "passenger vehicle” where it initially was acquired for personal use and subsequently began to be used primarily as a taxi, CRA noted that this definition turned on that of "automobile," which excluded a motor vehicle acquired primarily for use as a taxi and that, by virtue of a deemed acquisition under the change of use rules in s. 13(7), the “acquired primarily for use as a taxi” condition is satisfied on the change of use. ...

15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) dual-currency filing of s. 85 elections where the transferor and transferee have different tax reporting currencies Where the parties to a s. 85 rollover transaction have different tax reporting currencies (as defined in s. 261(1)), in what currency should the amounts be reported on the form T2057? ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Paragraph 5901(2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b) no relief for late-filed Reg. 5901(2)(b) election In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Net Earnings Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1)- Net Earnings surplus pools are not to be retroactively adjusted for a FACL carryback In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ...

27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business-- summary under Excluded Shares Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares exclusion for investment business or passive amounts not derived from a related business 29 May 2018 STEP Roundtable Q.7, 2018-0744031C6 indicated that the shares of a corporation that did not generate business income (e.g., a corporation that generated rents that, given the level of activity, constituted income from property) cannot qualify as excluded shares, whereas in Examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults (December 13, 2017), shares of a corporation earning income from passive investment assets qualified as excluded shares. ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Subclause 95(2)(a)(ii)(D)(I) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(D)- Subclause 95(2)(a)(ii)(D)(I) acquisition of shares that were not excluded property qualified under current use test FA Finco (a foreign affiliate of Canadian Parent) lends to FA Holdco (a Delaware subsidiary of Canadian Parent), which uses the borrowed money to acquire all of the shares of FA Target, which are not excluded property. ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Subclause 95(2)(a)(ii)(D)(III) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(D)- Subclause 95(2)(a)(ii)(D)(III) in light of the current-use test, borrowed money used to acquire shares that were not excluded property could satisfy s. 95(2)(a)(ii)(D) FA Finco (a foreign affiliate of Canadian Parent) lends to FA Holdco (a Delaware subsidiary of Canadian Parent), which uses the borrowed money to acquire all of the shares of FA Target, which are not excluded property. ...

4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement-- summary under Subsection 87(8.4) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(8.4) the Explanatory Notes on s. 87(8.4) partially conflated it with s. 87(8) The Explanatory Notes to ss. 87(8.4) and (8.5) provide: New subsections 87(8.4) and (8.5) allow taxpayers to elect for dispositions of taxable Canadian property (“TCP”) that is shares of a corporation or an interest in a partnership or trust to occur on a tax-deferred (“rollover”) basis, where the disposition results from a foreign merger that meets certain conditions. ...