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2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.7, 2016-0674811C6 F- Allocations automobiles & dépenses afférentes-- summary under Paragraph 8(1)(h.1) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) if vehicle allowance is too low, employee can include the allowance and deduct the vehicle expenses/T2200 production expected In discussing the situation where an employer limits the number of kilometers travelled by an employee in the course of employment for which it will pay a per-kilometer allowance, e.g., where the employer will stop paying once 10,000 kilometers have been driven in any year, or it does not pay for the first 20 km travelled in each employment-related trip, CRA stated: In such cases, an allowance may not be high enough in relation to expenses that an employee is expected to incur in a specific situation, and thus not be reasonable. ... An employee may, however, if all of the requirements are met, claim the deductions provided in paragraphs 8(1)(h), (h.1) or (j). … In addition, the CRA has stated…that where an employee elects to include in income the amount of a non-taxable motor vehicle allowance, the taxpayer can deduct the expenses for that vehicle which were actually incurred and which are otherwise deductible on condition that the taxpayer can demonstrate that such expenses are in excess of the allowance in question. ...

6 October 2017 APFF Roundtable Q. 14, 2017-0720321C6 F- GAAR & 21-year rule planning-- summary under Paragraph 104(4)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(4)- Paragraph 104(4)(a) Act does not contemplate any deferral beyond 21 years while property is directly in a discretionary trust or through a Canco If the terms of a discretionary family trust (“Old Trust”) so permit, the trustees (as the 21 st anniversary approaches) could choose to distribute the trust property to a corporate beneficiary (“Canco”), whose shares are held by a new discretionary trust (“New Trust”). ... CRA then stated: Our response would not be different even if the transactions put in place ensured that the realization of the capital gain inherent in the transferred property could not be postponed beyond the lifetime of the Old Trust's discretionary beneficiaries, who could have received property directly before the 21st anniversary. … [T]he Act does not contemplate any deferral beyond a 21-year period while property is directly or indirectly held in a discretionary trust and therefore, this situation raises the same policy concerns as in the situation described above. ...

5 May 2021 IFA Roundtable Q. 3, 2021-0888281C6- IFA 2021 Q.3: 247(3)- C$5 M Threshold & 261(5)-- summary under Paragraph 261(5)(b) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(5)- Paragraph 261(5)(b) the C$5M threshold in s. 247(3)(b)(ii) is to be translated into a functional currency on the basis that it is not “in respect of a penalty” Where a Canadian corporation (“Canco”) with an “elected functional currency” is subject to “transfer pricing income adjustments” respecting a “functional currency year” (as defined in ss. 261(1), 247(1) and 261(1), respectively),what relevant spot rate would be used to convert the C$5,000,000 threshold stated in s. 247(3)(b)(ii) into the elected functional currency, having regard to the statement in s. 261(5)(b) that, unless the context otherwise requires, each collar amount reference in the Act “other than in respect of a penalty or fine” is to be expressed in the taxpayer’s elected functional currency using the relevant spot rate for the first day of the particular taxation year in issue. ... The amount of the penalty itself is equal to 10% of the amount determined under paragraph 247(3)(a) and does not take into account paragraph 247(3)(b). … [P]redictability should prevail in applying subsection 247(3), and the application of paragraph 261(5)(b) to identify the “relevant spot rate” as the relevant spot rate for the first day of the particular taxation year when converting the C$ 5,000,000 threshold under subparagraph 247(3)(b)(ii) is consistent with that goal. ...

25 November 2021 CTF Roundtable Q. 4, 2021-0912111C6- Liable To Tax & Territorial Taxation-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 a Singapore corporation was a resident there for Treaty purposes – even though it was subject to tax on a territorial basis- provided its CMC was there Generally, a person must be “liable to tax” in a contracting state to be a resident there for treaty purposes. ...

3 May 1994 Roundtable Q. 1, 9411620- SAFE INCOME & ALBERTA ROYALTY TAX CREDITS-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Because an Alberta royalty tax credit is not included in a corporation's income for tax purposes, it also is not included in its safe income or safe income on hand. ...

7 October 2005 APFF Roundtable Q. 13, 2005-0141061C6 F- Purchase of Shares by Subsidiary- Sec. 84.1 & 245-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) S.245(2) generally would not apply where an individual ("X") owning 20% of the shares of Opco disposes of his shares of Opco to a newly-incorporated subsidiary of Opco for cash, provided that cash or near-cash does not constitute a significant portion of Opco assets, Opco continues to carry on its business, and Subco and Opco merge following this transaction. ...

8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10-- summary under Subsection 207.6(2) Summary Under Tax Topics- Excise Tax Act- Section 207.6- Subsection 207.6(2) In response to a question as to whether CRA has considered whether subsection 207.6(2) could apply to segregated fund policies and if yes, in what circumstances, CRA stated: [S]ince the definition "life insurance policy" in subsections 138(12) and 248(1) of the Act includes a segregated fund policy, we agree that such policies fall within the scope of the rule. ...

Between Sub. 13(21.2) & 88(1) of ITA-- summary under Subsection 13(21.2) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(21.2) Where a subsidiary corporation has had s. 13(21.2) apply to a transfer of depreciable property to its parent corporation, and the subsidiary is then wound up under s. 88(1), ss. 88(1)(e.2) and 87(2)(g.3) will deem the parent corporation to be a continuation of the subsidiary corporation for the purposes of applying the rules in s. 13(21.2) to the parent corporation in respect of the denied terminal loss. ...

23 March 2021 TEI Roundtable, 2021-0879631C6- CERS- Net Leases, Qualifying Revenue & Deadlines-- summary under Subsection 125.7(2.1) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(2.1) table of filing deadlines What are the deadlines to file an application for the CEWS and the CERS? ...

21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 10 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 10 In the Prévost Car case, "the Court implied that where an intermediary acts as a mere conduit or funnel in respect of an item of income, the intermediary would not have sufficient economic entitlement to the income to be considered the 'beneficial owner'. ...