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10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 6, 2024-1023301C6 F- CELIAPP- Séparation / FHSA- Separation-- summary under Subsection 146.6(7) Summary Under Tax Topics- Income Tax Act- Section 146.6- Subsection 146.6(7) s. 146.6(7) does not override the requirement for the transferee (ex-)spouse to be a “qualifying individual” Can an individual who does not have a FHSA and who does not qualify as a “qualifying individual” at the time of the transfer as a result of a relationship breakdown described in s. 146.6(7)(a)(ii) open a FHSA to receive the transfer from the individual’s spouse's or former spouse's FHSA? ...

10 October 2024 APFF Roundtable Q. 11, 2024-1028921C6 F- Récupération d’amortissement liée à un bien de la catégorie 10.1 – travailleur autonome-- summary under Class 10.1 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 10.1 choice between technical and simplified method where mixed business and personal use CRA considers that the CCA deduction for the motor vehicle of a self-employed worker that is used for both business and personal use can be computed by determining the amount of CCA in respect of the motor vehicle as if it were used entirely for business purposes, while deducting annually only the proportion of CCA corresponding to the business use in the particular year. ...

20 June 2023 STEP Roundtable Q. 3, 2023-0968091C6- Trust Reporting – Definition of Money and Treatment of Dividend Receivable-- summary under Subparagraph 150(1.2)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(b)- Subparagraph 150(1.2)(b)(i) gold or silver bar or coin would not qualify as “money”/ dividend receivable not included in “shares” Pursuant to s. 150(1.2)(b), the exception from trust reporting requirements under s. 150(1.1)- that may be available to individuals with no Part I tax payable or relevant dispositions- can apply to a trust for a particular tax year where the trust holds assets restricted to listed types of property including “money,” with an FMV not exceeding $50,000 throughout the year. ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Shares Summary Under Tax Topics- General Concepts- Fair Market Value- Shares premium for voting rights The questioner referenced the CRA statement at the 2009 British Columbia Tax Conference that, in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of the estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, CRA generally accepts that no premium should be attributed to such shares in determining their fair market value under s. 70(5), and asked whether this position also applies for the purposes of s. 104(4)(a), e.g., re the deemed disposition arising on the death of the spouse who is the beneficiary of a spousal trust. ...

28 May 2015 IFA Roundtable Q. 5, 2015-0581531C6- IFA 2015 Q.5: "Causality test" in 18(6) & 212(3.1)-- summary under Paragraph 18(6)(c) Summary Under Tax Topics- Income Tax Act- Section 18- Subsection 18(6)- Paragraph 18(6)(c) "because of" causality test What is the requisite degree of linkage referenced by the "because" test in clause (B) of ss.18(6)(c)(i), 18(6)(c)(ii), 212(3.1)(c)(i) and 212(3.1)(c)(ii) (the "Clause B causality tests") between a debt owing by the taxpayer to a creditor and a secondary obligation existing between that creditor (or someone not dealing at arm's length with that creditor) and certain non-residents, so as to engage s. 18(6.1) or 212(3.2)? ...

16 June 2014 STEP Roundtable, 2014-0523091C6- STEP CRA Roundtable – June 2014-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) bequests to both spouse and common law spouse Can s. 70(6) apply to a transfer by a taxpayer both to his or her spouse and a transfer to his or her common law spouse? ...

12 June 2012 June STEP Roundtable, 2012-0442681C6- STEP CRA Roundtable – June 2012- Question 2-- summary under Subsection 160(1) Summary Under Tax Topics- Income Tax Act- Section 160- Subsection 160(1) In response to a question as to whether a s. 160 would a apply to a butterfly reorganization (which typically entailed two share redemptions giving rise to deemed dividends), where the reorganization was intended to divide family assets between spouses in a divorce situation, CRA stated: [I]t would be a question of fact as to whether subsection 160(1) would apply to any of the transfers of property that would form part of the transactions involved in the reorganization. ...

LLPs & LLLPs-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation Delaware and Florida LLPs and LLLPs as corporations CRA indicated that it has finalized its view that Florida and Delaware limited liability partnerships and limited liability limited partnerships are corporations for ITA purposes in light inter alia of their separate legal personality and limited liability for all members (and noted that "we see little substantive difference between LLPs, LLLPs and LLCs governed by the laws of the states of Florida and Delaware. ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Subsection 93.2(3) Summary Under Tax Topics- Income Tax Act- Section 93.2- Subsection 93.2(3) s. 95(2)(c) rollover can apply on a dropdown of shares made to an LLC as a contribution of capital rather than for “share” consideration Canco owns all the shares of FA1, which owns all the shares of FA2 and all the member interests of FA3, which is a “non-resident corporation without share capital” as per s. 93.2(1). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Paragraph 95(2)(c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(c) dropdown of shares made to an LLC as a contribution of capital deemed by s. 93.2(3) to be for "share” consideration FA1 (wholly-owned by Canco) transfers all of the shares of FA2 to another non-resident subsidiary of FA1, viz., a non-share corporation (“FA3”), as a capital contribution, i.e., no new member interests are issued by FA3. ...