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Reasons: See below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 9. ...

Based upon its success and reception by the tax service industry, the Government announced in Budget 2019 that it would provide ongoing funding to make the well-received DTS program permanent, improving service for the millions of Canadians who work with tax service providers each year. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 18. ...

Reasons: Legislation and previous positions. 2019 CTF Annual Conference CRA Roundtable Question 8: TOSI – Excluded Business The definition of an excluded amount in subsection 120.4(1) of the Act allows an exemption from the application of tax on split income (TOSI) provided the dividend be derived directly or indirectly from an excluded business of the individual for the year. ...

Reasons: See Below. 2020 STEP CRA Roundtable – November 26, 2020 QUESTION 9. ...

Reasons: Legislation and previous positions. 2020 STEP CRA Roundtable – November 26, 2020 QUESTION 10. ...

Reasons: See below. 2020 STEP CRA Roundtable – November 26, 2020 Question 3. ...

Reasons: The transaction described circumvents the application of subsections 107(5) and 107(2.1). 2020 STEP CRA Roundtable – November 26, 2020 QUESTION 12: Distribution of Property by a Canadian Resident Trust to a Canadian Corporation that is Wholly Owned by One or More Non-Residents At the 2017 CTF Annual Conference the CRA addressed a situation involving the distribution of property by a Canadian resident discretionary trust to a Canadian corporation whose shares would be wholly owned by a non-resident beneficiary. ...

Reasons: See below. 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 6. ...

Reasons: For the purposes of paragraph 55(2.1)(c) safe income is adjusted to take into account only the portion of safe income that can reasonably be considered to contribute to the capital gain on a share. 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 9. ...

Reasons: See below. 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 10. ...