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6 October 1995 APFF Roundtable Q. 16, 9522320 F- QUESTION TABLE RONDE APFF- 1995 # 16- 74.4(2) Unedited CRA Tags 74.4(2) 74.5(5) 74.4(4) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

29 November 1995 CTF Roundtable Q. 1, 6M11910- TRANSFERS OF PROPERTY TO PROTECTIVE & BARE TRUSTS Unedited CRA Tags 54(e) Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department. ...

27 November 2018 CTF Roundtable Q. 13, 2018-0779991C6- 20(1)(c) & Triangular Amalgamation Unedited CRA Tags 20(1)(c), 87(9) Principal Issues: Whether interest on borrowed funds, used to redeem preferred shares issued as part of a triangular amalgamation governed by subsection 87(9), is deductible under paragraph 20(1)(c)? ...

15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6- 78(1)(b)(ii) deemed loan & thin capitalization Unedited CRA Tags 78(1), 18(4), 18(5), 20(1)(c), 20(1)(d) Principal Issues: 1. ...

25 November 2021 CTF Roundtable Q. 4, 2021-0912111C6- Liable To Tax & Territorial Taxation Unedited CRA Tags Article IV of a Tax Treaty. ...

30 November 2021 Roundtable, 2021-0914531C6- 2021 TEI – Q3A- Section 87 Indian Act Unedited CRA Tags 81(1)(a) Principal Issues: Question concerning CRA's administration of the Indian Act Exemption for Employment Income Guidelines. ...

23 March 2021 TEI Roundtable, 2021-0879631C6- CERS- Net Leases, Qualifying Revenue & Deadlines Unedited CRA Tags 125.7 PRINCIPAL ISSUES: 1- Various questions on the eligibility of utilities expenses for the CERS 2- Does an eligible entity have to compute its qualifying revenue using the same approaches and elections for both the CEWS and the CERS for a particular qualifying period? ... REASONS: 1- Wording of the Act 2- Wording of the Act 3- Wording of the Act TEI 71st Virtual Midyear Conference – March 22 to 25, 2021 CRA Roundtable Question 1- CERS and Net Leases The Canada Revenue Agency has received a number of questions from taxpayers and their representatives about qualifying rent expenses and, in particular, whether utilities paid by a tenant may be claimed under the Canada Emergency Rent Subsidy (or “CERS”). ...

18 June 2015 STEP Roundtable Q. 10, 2015-0578541C6- 2015 STEP – Q10- Interest in a Trust as TCP CRA Tags 116(5.01) 116(6.1) 116(5.02) 116(6) 116(5) 248(1) Principal Issues: A testator leaves an estate, more than 50% of which is comprised of real property situated in Canada, (the testator's principal residence). ...

29 November 2016 CTF Roundtable Q. 1, 2016-0669301C6- GAAR & 21-year rule planning Unedited CRA Tags 104(4); 104(5.8); 107(2); 245 Principal Issues: Implications of a transfer of property from a discretionary trust to a Canadian corporation wholly owned by a new discretionary trust Position: CRA will typically apply GAAR in this situation. ...

8 October 2004 Roundtable, 2004-0086811C6- Shares Held by an Individual & Exempt Surplus Unedited CRA Tags Reg. 5907 12(1)(k) 113(1)(a) 90 Principal Issues: Can an individual who owns all the shares of a non-resident corporation transfer his shares to a Canadian corporation and benefit from the exempt surplus treatment under the Act on the income of the foreign corporation earned before the transfer to a Canadian corporation? ...