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7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business royalty income from a music composing business is active business income Gagliese Productions found that royalty income of an author/musician was income from services because the person who derived the income was earning the income in the normal course of his business. ...

10 October 2024 APFF Roundtable Q. 2, 2024-1028371C6- Transfert intergénérationnel d’entreprise – nouvelles règles-- summary under Paragraph 84.1(2.32)(a) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2.32)- Paragraph 84.1(2.32)(a) s. 84.1(2)(e) exception is available only for the 1st disposition if the subject corporation shares are sold in tranches A parent wishes to access the s. 84.1(2.31) or (2.32) rules regarding a transfer of the shares of Parent Inc. ...

10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 5, 2024-1023291C6 F- Paiements rétroactifs- Droits ou biens / Retroact-- summary under Subsection 70(2) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(2) s. 70(2) return can be filed before the filing deadline with an estimated amount if precise amount is not yet known due to administrative delay A taxpayer died in October 2021 after a pay equity settlement was reached with the Quebec government in June 2021. ...

. … … 2019-0799901C6 … and … Example 9 of … Guidance on the Application of the Split Income Rules for Adults provide useful general guidance …. In particular … 2019-0799901C6 … indicated that a husband and wife could both be considered to be actively engaged in the activities of a particular business carried on by their corporation on a regular, continuous and substantial basis for a particular year where the particular business did not require any other workers and only required them to spend on average 5 hours each per week in that business. ...

11 May 2005 Roundtable, 2005-0127081C6 F- États financiers- Impôt de la Partie I.3-- summary under Subsection 181(3) Summary Under Tax Topics- Income Tax Act- Section 181- Subsection 181(3) GAAP refers to Canadian GAAP Where a Canadian public corporation prepares its financial statements in accordance with US GAAP, will this be accepted as GAAP under s. 181(3)(b): CRA responded: GAAP refers to the current accounting standards or principles established by the … CICA …. … Where the balance sheet is prepared in accordance with U.S. ...

In addition, the CRA generally considers that the Purpose Tests [in ss. 55(2.1)(b)(i) and (ii)] could apply to a dividend paid by an operating company to its corporate shareholder in order to dispose of surplus assets for the purpose of the purification and subsequent sale of [its] shares … 2017-0724021C6 …. … [T]he payment of the Dividend and the Sale are part of the same series …. ... Consequently, subsection 55(2) should likely apply …. ...

29 August 2023 CPAC Roundtable Q. 8, 2023-0983051C6- Automobile Expenses-- summary under Paragraph 8(1)(h.1) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) Gardner (re deducting a sales person’s expenses of occasional travel between her home office and her employer) will be followed only on similar facts Regarding the deductibility of automobile expense incurred by an employee, with a fully remote work arrangement, in connection with an occasional visit to the office from the home office, CRA stated: [T]raveling between an employee’s home, including a home office, and a regular place of employment (RPE) is generally considered personal travel …. … In this case, “regular” means there is some degree of frequency or repetition in the employee’s reporting to that particular location in a given pay period, month, or year. … For example, a work location may be considered to be a RPE of an employee even though the employee may only report to work at that particular location on a periodic basis (e.g., once or twice a month) during the year. Depending on the circumstances, an employee may have more than one RPE. … … [Although] Gardner … held that motor vehicle expenses related to an employee’s travel between their home office and the employer’s principal place of business were deductible employment expenses under paragraph 8(1)(h.1) … the CRA’s general position on travel between an employee’s home or home office and a location that is a RPE for that employee remains unchanged. ...

Subject to certain exceptions under subsection 4(3) … subsection 4(2) … specifically denies the deduction of items in sections 60 to 64 … in determining income from a particular source. Consequently, a deduction allowed under paragraph 60(s) … is not tied to a particular source …. The amount determined under paragraph 3(c) … which forms variable F of the “non-capital loss” definition in subsection 111(8) … will never be negative, and therefore deductions described in Subdivision E of the Act cannot create or increase the amount of a non-capital loss. ...

After noting that the Finance Technical Notes indicated that this “election is meant to allow the shareholders of a foreign affiliate to access their capital first as measured by the adjusted cost base … of the shares,” CRA stated: Even though the preamble of paragraph 5901(2)(b) … does not specify to whom the “whole dividend” … is paid … based on a contextual and purposive analysis … the “whole dividend” … is a reference to a dividend that would cause a consequential ACB adjustment to the shares of the foreign affiliate on which it is paid, if a Regulation 5901(2)(b) election could be made in respect of that dividend. ...

With respect to the expression “in any manner whatever’ in subsection 84(2), the Court noted that “ [t]hese far-reaching words are anchored in history as they have always been part of this provision, and they faithfully reflect its anti-avoidance purpose”. ... It should also be noted that the Federal Court of Appeal also resolved the uncertainties arising from certain decisions that taxpayers frequently invoked against the application of subsection 84(2), namely McNichol … Descarries … and Robillard …. ... CRA also indicated that “ Foix did not express an opinion on the Tax Court of Canada's analysis in Geransky ” and implied that Gernasky has been overtaken by the subsequent decisions of the Federal Court of Appeal in MacDonald and Foix, which “clearly ruled that subsection 84(2) should be interpreted broadly.” ...