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Reasons: Scheme of the Act. 2022 CALU CRA Roundtable – May 2022 Question 5- Policy Loan and Deduction under Paragraph 60(s) Background For the purposes of section 148 of the Income Tax Act (the “Act”), taking a policy loan under a life insurance policy is a disposition of an interest of a life insurance policy. ...

CALU Roundtable- May 2022 Question 7 – Life insurance shares Background The CRA has previously considered life insurance shares in the context of determining how the cash surrender value (CSV) of a corporate-owned life insurance policy is allocated between various classes of shares including life insurance shares, for the purposes of subsection 70(5.3) of the Income Tax Act (the “Act”) on the death of a shareholder. ...

Reasons: On the facts of this Question 14 and on the assumption that the partnership is the relevant taxpayer in subsection 90(3), there is no connected person or partnership in respect of the taxpayer as defined in subsection 90(4). 2022 International Fiscal Association Conference CRA Roundtable Question 14 – Partnership and Subsection 90(3) Election A distribution made by a foreign affiliate of a taxpayer in respect of a share of its capital stock will be a qualifying return of capital pursuant to subsection 90(3) of the Act where the following conditions are met: (i) the distribution is a reduction of the paid-up capital of the foreign affiliate in respect of the share, (ii) the distribution would otherwise be deemed under subsection 90(2) to be a dividend paid or received on the share, and (iii) an election is made in respect of the distribution in accordance with prescribed rules. ...

The election can only be made by an alter ego trust, the terms of which are described in clause 104(4)(a)(iv)(A). 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 2. ...

Reasons: Based on the CRA’s long-standing position on debt settlement in various factual situations relevant to this issue. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 5. ...

Reasons: See below. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 12. ...

Reasons: See response below. 2022 STEP CRA Roundtable – June 15, 2021 QUESTION 4. ...

As any tax-free surplus grind to the bump would result in a gain on disposition which would be eliminated with a 93(1) election, the requirement for tax-free surplus calculations would be a redundant exercise since surplus available for a 93(1) election would generally equal the tax-free surplus balance. 2023 IFA Annual Conference CRA Roundtable Question 8 – Tax-free Surplus Balance Calculation and Paragraph 88(1)(d) “Bump” At the 2011 IFA Conference CRA Roundtable (CRA document 2011-0404521C6), the CRA indicated that it would not challenge a paragraph 88(1)(d) bump in respect of the shares of a foreign affiliate (FA) by raising an issue with an FA’s tax-free surplus balance (TFSB) calculation or lack thereof in circumstances where, absent clause 88(1)(d)(ii)(C), the shares of FA could be bumped to fair market value such that there would be no gain on a subsequent distribution of the FA shares to a foreign parent, provided that no dividends were paid or were deemed to be paid on the FA shares following the acquisition of control and the FA shares were distributed to the foreign parent within a reasonable amount of time. ...

Although the CRA may provide relief in respect of the provision of prescribed information normally required in foreign reporting forms, the forms must still be filed by the taxpayer on or before the respective form’s filing due date. 2023 International Fiscal Association Conference CRA Roundtable Question 2 – Ukraine/Russia Reporting Requirements Some Canadian multinationals have subsidiaries in Ukraine or Russia that continued operating during 2022 in those countries. ...

CALU Roundtable- May 2024 Question 7 – Prescribed Annuity Contracts and Trusts A prescribed annuity contract (PAC) is a type of immediate annuity contract (i.e. payments have commenced) that is not subject to annual accrual tax reporting under subsection 12.2(1) of the Income Tax Act (the “Act”) by virtue of the exception set out in paragraph 12.2(1)(b) of the Act. ...