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25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Clause 95(2)(a)(ii)(B) 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)(B) application of current use test under s. 20(1)(c) FA Finco, a foreign affiliate of Canadian Parent, lends money to FA Acquireco LLC (a US fiscally-transparent subsidiary of FA Holdco (which is a non-transparent Delaware subsidiary of Canadian Parent) to acquire all the shares of FA Target LLC (also fiscally transparent), which is merged into FA Acquireco LLC (renamed “Mergeco LLC”). ... Since Mergeco is a disregarded entity, Reg. 5907(1) – earnings – (a)(iii) requires such earnings to be computed under Part I for such purposes. This wording engages the current use test under s. 20(1)(c) – which should be satisfied since the Mergeco property would be used in an active business. ...

3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan-- summary under Private Health Services Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan a health spending account for a single shareholder/employee likely does not qualify as a PHSP Can a health spending account (HSA) (under which an employer agrees to reimburse its employees’ hospital and medical expenses incurred during the year up to a pre-determined limit) established for a single shareholder/employee (and family members) qualify as a private health services plan (PHSP)? CRA responded: [F]or a plan to be a PHSP … the plan must be a plan of insurance. ... Therefore, it … would likely not constitute a plan in the nature of insurance and consequently, would not qualify as a PHSP. ...

3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan-- summary under Subparagraph 6(1)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a)- Subparagraph 6(1)(a)(i) single shareholder/employee HSA does not qualify S. 6(1)(a)(i) excludes a taxable benefit from the employer’s funding of a private health services plan (PHSP) for its employees, including in the case of a health spending account (HSA) (under which an employer agrees to reimburse its employees’ hospital and medical expenses incurred during the year up to a pre-determined limit). ... This is based on its view that “for a plan to be a PHSP … the plan must be a plan of insurance” and, here, “[e]ffectively, the sole employee-shareholder is paying for the personal hospital and medical expenses for themselves and their family members through their solely owned corporation without any risks being assumed by the corporation.” ...

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? ...

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? ...

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. ...

18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6- 2015 STEP – Q2 – Meaning of Graduated Rate Estates-- summary under Graduated Rate Estate Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Graduated Rate Estate one estate even if multiple wills (see also summary of initial response at 19 June 2015 STEP Roundtable, oral Q.2(a)) If an estate for a deceased who passed away after 2015 is under administration in its first 36 months, will it be considered a graduated rate estate in its entirety, even if there are two wills. ...