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Summary of 2024 Ruling 2024-1008821R3 F under s. 55(1) – distribution. ...

Regarding the payment of “interest” on any preferred shares held by members, this would constitute in substance a distribution of the cooperative’s profits to them and, thus, be offside – and indeed, the mere issuance by it of such shares would put it offside even if no such interest was paid. ...

Under s. 212.3(1)(b), the s. 212.3 rules apply to an investment made by the CRIC in a subject corporation if as part of the series of transactions that includes the making of the investment, Forco acquired control of the CRIC and at the time of the “investment”, the Forco shares represented 25% or more of the votes or value of the CRIC – with s. 251(5)(b) rights being taken into account for these purposes. ...

Summary of 2022 Ruling 2021-0911791R3 F under s. 55(1) – distribution. ...

Summary of 2024 Ruling 2023-0998291R3 F under s. 55(1) – distribution. ...

However, as the unanticipated fugitive emissions occurred within Bco’s pipeline transportation network, “Aco may be able to avail itself of the relief provided in subsections 211.92(6) and (7) … because such emissions would likely be due to extraordinary circumstances outside of the control of Aco.” ...

19 June 2025- 12:21am CRA indicates that the children receiving an intergenerational transfer may control the purchaser corporation indirectly or as trustees of a trust Email this Content Our 2025 STEP Roundtable page- which provides the questions posed, and summaries of the preliminary oral responses given, at the 2025 STEP CRA Roundtable held on Tuesday – is now available. ...

However, if the agreed amount was greater than the property’s capital cost so as to realize a portion of the accrued capital gain, then s. 12(12) would apply so as to deem the property to be real estate inventory that was not an “eligible property,” thereby rendering the s. 85(1) election invalid – so that the full accrued gain would be business income. ...

Topic Descriptor 21 November 2017 CTF Roundtable Q. 1, 2017-0724301C6- 21 year planning & NR beneficiary Income Tax Act- 101-110- Section 107- Subsection 107(5) GAAR very well may apply to s. 107(2) distribution to Canco owned by NR beneficiary 21 November 2017 CTF Roundtable Q. 2, 2017-0724121C6- Trusts and principal residence Income Tax Act- Section 54- Principal Residence- Paragraph (c.1) right to use property of life interest housing trust would not be a right to use the house as a residence 21 November 2017 CTF Roundtable Q. 3, 2017-0724021C6- Meaning of purpose Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) QSBC purification transaction must not have any bad purpose described in s. 55(2.1)(b), as determined objectively as per Ludco 21 November 2017 CTF Roundtable Q. 4, 2017-0724051C6- Timing of deemed gain under 55(2) Income Tax Act- Section 89- Subsection 89(1)- Capital Dividend Account- Paragraph (a) an immediate CDA addition for a non-redemption dividend subject to s. 55(2) Income Tax Act- Section 55- Subsection 55(2)- Paragraph 55(2)(c) immediate CDA addition for s. 55(2)(c) dividend 21 November 2017 CTF Roundtable Q. 5, 2017-0726381C6- 55(5)(f) and 55(2.3) with 55(2.1) Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(b) notwithstanding dividend bifurcation under s. 55(5)(f) (or 55(2.3), the s. 55(2.1)(b) purpose test is to be applied to the whole dividend Income Tax Act- Section 55- Subsection 55(5)- Paragraph 55(5)(f) bifurcated dividends are one dividend for s. 55(2.1)(b) purpose test but not under s. 55(2.1)(c) Income Tax Act- Section 55- Subsection 55(2.3) dividend bifurcation under s. 55(2.3) does not detract from s. 55(2.1) purpose tests being applied to whole dividend 21 November 2017 CTF Roundtable Q. 6, 2017-0724071C6- Circular calculations Part IV tax Income Tax Act- Section 186- Subsection 186(1)- Paragraph 186(1)(b) refunded Pt IV tax payable not reduced by application of s. 55(2) Income Tax Act- Section 55- Subsection 55(2) where Holdco receives a dividend subject to refundable Pt IV tax and to s. 55(2), two different dividends should be reported for Pt IV and s. 55(2) purposes 21 November 2017 CTF Roundtable Q. 7, 2017-0724261C6- CRA Update Statutory Interpretation- Interpretation Bulletins, etc. 265 IT Bulletins are being replaced by Folios 21 November 2017 CTF Roundtable Q. 8, 2017-0724151C6- Principal Purpose Test Treaties- Multilateral Instrument- Article 7- Paragraph 7(1) central CRA committee may review PPT assessments/rulings available/uncertain relevance of GAAR jurisprudence 21 November 2017 CTF Roundtable Q. 9, 2017-0724191C6- Stock Option Deduction Income Tax Act- 101-110- Section 110- Subsection 110(1.1) s. 110(1.1) mechanism is available where employer is exempt employer deduction denied under s. 18(1)(b) or 7(3)(b) 21 November 2017 CTF Roundtable Q. 10, 2017-0724291C6- Tax Shelters Income Tax Act- Section 96- Subsection 96(2.2) no rulings on at risk rules’ application to tax shelter LPs 21 November 2017 CTF Roundtable Q. 11, 2017-0724081C6- ULC-LLC structures & Treaty Treaties- Articles of Treaties- Article 4 Treaty anti-hybrid rule (Art. 7(b)) rule applies to dividends paid by a ULC to two LLCs held by U.S. ...

These are additions to our set of 1,041 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¾ years of releases of Interpretations by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2019-12-18 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 2, 2019-0811881C6 F- HBP/HBTC- Death of a spouse Income Tax Act- Section 146.01- Subsection 146.01(1)- Regular Eligible Amount- Paragraph (f) widow who had resided in the home of her deceased husband could access the HBP program to purchase a condo or acquire his home from estate Income Tax Act- Section 118.05- Subsection 118.05(1)- Qualifying Home- Paragraph (a) widow who had resided in the home of her deceased husband could access the first-time home buyer’s credit 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 4, 2019-0813421C6 F- TFSA- Survivor Payment- Decrease in FMV Income Tax Act- Section 207.01- Subsection 207.01(1)- Exempt Contribution- Paragraph (b) survivor payment equals amounts paid under the TFSA to the estate provided the survivor receives at least that amount as TFSA beneficiary Income Tax Act- Section 207.01- Subsection 207.01(1)- Unused TFSA Contribution Room- Paragraph (b)- Element D diminution in TFSA property in executors' hands reduces exempt contribution 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 5, 2019-0820901C6 F- TFSA Exempt Contribution- Timing of contribution Income Tax Act- Section 207.01- Subsection 207.01(1)- Exempt Contribution- Paragraph (c) an exempt contribution to a TFSA can only be made as of right no more than 30 days before the survivor payment was received from an estate 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 6, 2019-0813451C6 F- TFSA- Bequest and disclaimer Income Tax Act- Section 207.01- Subsection 207.01(1)- Exempt Contribution- Paragraph (b) transfer of TFSA to surviving spouse because of daughter’s renunciation occurred as a consequence of the deceased’s death Income Tax Act- Section 248- Subsection 248(8)- Paragraph 248(8)(b) transfer of TFSA to survivor on renunciation of bequest thereof occurred as a consequence of death 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 7, 2019-0821701C6 F- TFSA Exempt Contribution- Survivor payment Income Tax Act- Section 207.01- Subsection 207.01(1)- Exempt Contribution- Paragraph (b) extension of rollover deadline through Ministerial discretion 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 8, 2019-0811901C6 F- RRIF – Minimum amount after death Income Tax Act- Section 146.3- Subsection 146.3(1)- Minimum Amount required recognition of RRIF minimum amount in post-terminal year of transfer of RRIF to surviving spouse Income Tax Act- Section 146.3- Subsection 146.3(6.11) deduction of RRIF minimum amount in post-terminal year of transfer out of deceased's RRIF to surviving spouse 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 9, 2019-0813281C6 F- Pension splitting- RRIF deemed benefit Income Tax Act- Section 118- Subsection 118(7)- Pension Income- Paragraph (a)- Subparagraph (a)(iii) deemed payment on death of last RRIF annuitant is not pension income Income Tax Act- Section 146.3- Subsection 146.3(6) s. 166.3(6) language does not go on to deem there to be payment by RRIF issuer 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 10, 2019-0812841C6 F- RESP- Change of subscriber Income Tax Act- Section 146.1- Subsection 146.1(6.1) amounts can be transferred from one RESP to another Income Tax Act- Section 204.9- Subsection 204.9(5)- Paragraph 204.9(5)(e) RESP transferor could be liable under s. 204.91(1) 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 11, 2019-0812971C6 F Income Tax Act- Section 2- Subsection 2(1) CRA uses information collected on an NR73 as its principal tool in assessing individuals’ residency 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 12, 2019-0815181C6 F- RRSP on death and refund of premiums Income Tax Act- Section 146- Subsection 146(8.1) post-death appreciation in an RRSP could qualify for a s. 146(8.1) rollover Income Tax Act- Section 146.3- Subsection 146.3(6.1) rollover of post-death RRIF income under s. 146.3(6.1) 2011-03-25 8 October 2010 Roundtable, 2010-0371901C6 F- avantage à l'actionnaire, assurance-vie Income Tax Act- Section 246- Subsection 246(1) CRA will examine if there is a s. 246(1) benefit where subsidiary is beneficiary of life insurance policy held and paid for by parent Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x) reimbursement by sub of premiums potentially includible under s. s. 12(1)(x) where it is the beneficiary of life insurance policy held by parent 8 October 2010 Roundtable, 2010-0378521C6 F- Déduction des primes d'assurance frais généraux Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose pro rata deduction of premiums for overhead expense insurance policy where other risks are also covered ...