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Situation 1 – If Individual A had designated three siblings as equal beneficiaries under the FHSA in accordance with provincial law, would each sibling be required to report $10,000 in Year 2? Situation 2 – If Individual A’s estate had been designated as beneficiary under the FHSA in accordance with provincial law, would it be required to report $30,000 in Year 2? Situation 3 – If Individual A had not designated any beneficiary under the FHSA so that the FHSA proceeds were payable to the individual’s estate, whose residual beneficiaries per the will were the three siblings, would the estate be required to report $30,000 in Year 2. ...

. … As a result [of s. 9(3)], the appreciation in the value of a property that is capital property … is not in itself a source of income that is property. ...

16 August 2022 CPAC Roundtable Q. 10, 2022-0946251C6- Home Office Expenses-- summary under Subparagraph 8(13)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(13)- Paragraph 8(13)(a)- Subparagraph 8(13)(a)(ii) s. 8(13)(a)(ii) does not extend to virtual meetings Regarding the impact of meeting clients in a home virtually, CRA stated: It is the long-standing position of the … CRA … that the term “meeting”, as used in both subparagraph 8(13)(a)(ii) and 18(12)(a)(ii) of the Act includes only face to face encounters. ...

4 June 2024 STEP Roundtable Q. 9, 2024-1020351C6- Paragraph 150(1.2)(b) and GICs-- summary under Paragraph 150(1.2)(b) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(b) holding any GIC would preclude a trust from qualifying under s. 150(1.2)(b) CRA indicated that a GIC issued by a Canadian bank or trust company did not constitute one of the assets listed in s. 150(1.2)(b), such as money, or a government issued or guaranteed debt obligation described in s. 212(3) – fully exempt interest – (a). ...

Accordingly, Child X receives the Class E shares (that had not previously been encroached on) on turning 36 – whereupon Child X requests their redemption, thereby resulting in the receipt of a deemed dividend of $100,000. ... X's will – would also be considered an acquisition of property made as a consequence of Mr. ... X's death – so that from that time on, the conditions in s. 120.4(1.1)(b)(ii) will be satisfied and the income from those shares (including the deemed dividend) will be an excluded amount to Child X. ...

CRA responded: … Easingwood does not stand for the general proposition that an Attorney may create such trusts for the grantor of a Power of Attorney for Property. … CRA would expect that an Attorney that is contemplating the creation of an alter ego trust would seek the affirmation of the applicable court that the particular terms of the Power of Attorney for Property provide for such a power and that the terms of the proposed trust conform with the terms of the existing will and any other relevant agreements. ...

As such … this amount would not qualify as an "income or profit tax". No foreign tax credit could be granted in respect of the excess amount. … In addition, it would not be deductible under subsection 20(11). ...

. … Furthermore, the courts have repeatedly emphasized that the safe income on hand of a corporation should not be subject to double taxation. … Moreover, in a situation where a corporation declines to deduct its safe income on hand from the taxable dividend subject to subsection 55(2), for example, in order to convert the safe income on hand into a capital gain as part of a surplus stripping scheme, we are of the view that subsection 245(2) could be invoked. ...

. … Our response would remain the same in the case of a painting located in the office of a director who does not receive clients in that office …. ...

Customized remittance vouchers for businesses can be obtained quickly and easily through the CRA Web site … or through the "My Business Account" service …. ...