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21 May 2009 IFA Roundtable Q. 1, 2009-0321451C6- Meaning of beneficial owner in Article 10, 11 & 12-- summary under Article 11 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 11 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'. ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Paragraph 104(4)(a) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(4)- Paragraph 104(4)(a) CRA generally will ignore any premium that could be attributed to controlling non-participating preference shares, for purposes of subsection 70(5) of the Income Tax Act (the "Act"), where the shares were held to protect the deceased's economic interest in the corporation. ...

5 October 2012 Roundtable, 2012-0453201C6 F- Règles d'attribution- séparation & décès-- summary under Subsection 13(1) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(1) recapture from rental property is property income from that property Before finding that there was no attribution of recapture of depreciation by virtue of the exception from the application of s. 74.1(1) contained in s. 74.5(3)(a), CRA stated, in its summary: [T]he nature of recapture of depreciation is analogous to the nature of the depreciation expense that was claimed in the past. ...

3 December 2013 TEI Roundtable, 2013-0510851C6- 2013 TEI – Question 9: Tax residency certificates.-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) no residency certificates for partnerships Would CRA be willing to issue Canadian tax residency certificates in the name of a Canadian partnership on the basis of the Canadian residency of all its partners? ...

30 October 2012 Ontario CTF Roundtable Q. 8, 2012-0462841C6- Ontario CTF – Q8 Residency of a Trust-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) trust residence following Fundy In response to a query on the Fundy Settlement case, CRA stated: Normally, residence of a trust is dependent upon residence of the trustee or trustees who can exercise management and control of the trust. ...

26 November 2013 Annual CTF Roundtable, 2013-0509061C6- Part XIII Tax & Standard Convertible Debentures-- summary under Paragraph 214(8)(c) Summary Under Tax Topics- Income Tax Act- Section 214- Subsection 214(8)- Paragraph 214(8)(c) interest and premium on standard convertible debenture not participating CRA is not inclined at this time to take the position that standard convertible debentures would in general constitute "excluded debt obligations" pursuant to paragraph 214(8)(c) of the ITA. ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election-- summary under qualified disability trust Summary Under Tax Topics- Income Tax Act- Section 122- Subsection 122(3)- qualified disability trust preferred beneficiary and QDT elections not mutually exclusive Where, for example, four grandparents each established a trust for their mutual disabled grandchild under their wills, with one of the trusts (after death) now being intended to be a qualified disability trust, CRA confirmed that the designation of that trust as a QDT would not restrict the availability of the preferred beneficiary election for the other three trusts (and the fourth trust could make the preferred beneficiary election even if it had elected to be a QDT). ...

LLPs & LLLPs Classification-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation perhaps potential flexibility in applying the transition of LLPs from partnerships to corporations CRA largely repeated its position immediately below in 2016 IFA Roundtable, Q. 1 (as well as indicating that Anson has not changed its views on LLCs). ...

7 October 2016 APFF Roundtable Q. 9, 2016-0652921C6 F- Résidence- actif utilisé / Residence- asset used-- summary under Share of the Capital Stock of a Family Farm or Fishing Corporation Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Share of the Capital Stock of a Family Farm or Fishing Corporation primary employee use qualifies farm house CRA will accept that a farm house is an active business asset for purposes of the definitions of “qualified small business corporation share,” “share of the capital stock of a family farm or fishing corporation” and "interest in a family farm or fishing partnership" if it is used more than 50% by farming employees who are providing their services in that capacity rather than as shareholder (or partner). ...

16 May 2018 IFA Roundtable Q. 9, 2018-0748151C6- T1134s & Country by Country Reporting-- summary under Subsection 233.4(4) Summary Under Tax Topics- Income Tax Act- Section 233.4- Subsection 233.4(4) comparison of T1134 and CbC reporting Although the mandated requirement is a Finance requirement, what is CRA’s perspective on whether there is a need for T1134 filing in addition to the mandated country-by-country reporting? ...