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It is a question of fact when the property is transferred or distributed to and vests indefeasibly in a testamentary spousal trust. 2017 STEP CRA Roundtable – June 13, 2017 QUESTION 11. ... CRA Response At the 2015 Conference of the “Association de planification fiscale et financière” (APFF), the CRA commented on whether the rollover under subsection 70(6) would apply if the executor of an estate disposed of property of the estate and transferred the proceeds, or property substituted for those proceeds, to a spousal trust created by the will of the deceased (Question 9 – CRA Document 2015-0596611C6). ...

IFA 2018 International Tax Conference Canada Revenue Agency Roundtable Question 7 – Undertaking to Repay and subsection 39(2) Consider the following hypothetical facts: Canco owns 100% of the common shares of Canco 1 which owns 100% of the common shares of Canco 2. ... Jack Chang / Yves Moreno 2018-075026 May 16, 2018 ...

Reasons: See below. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 8. ... In rendering its decision, the Tax Court rejected the appellant’s argument that there is an alternative method whereby the IRA should be treated as an investment portfolio – and in doing so, clarified that clause 56(1)(a)(i)(C.1) correctly applied to include the amount received in income. ...

Reasons: Previous positions. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 2. ... Tara Mathanda 2018-074410 FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 See 2007 Question 3 (CRA document # 2007-0233721C6), 2012 Question 8 (2012-0442931C6), 2015 Question 2 a) (2015-0572091C6) and 2016 Question 1 a) (2016-0634871C6). 2 Where the testamentary trust is established for the testator’s spouse or common-law partner, the deemed disposition of the trust’s property occurs on the beneficiary’s death, pursuant to paragraph 104(4)(a). ...

Capital Cost Allowance – Elections to Include Properties in Class 1 Under Part XI of the Income Tax Regulations, a taxpayer’s depreciable property is grouped into various classes described in Schedule II. ... Interpretation Bulletin IT-327, Capital Cost Allowance – Elections under Regulation 1103, has been cancelled and information regarding the election under subsection 1103(1) has been incorporated into paragraph 1.132 of Income Tax Folio S3-F4-C1, General Discussion of Capital Cost Allowance (the “Folio”). ...

· If:- Canco's only client is USCo, or- Canco has several clients, including USCo; ·If:- Canco does not own any share in the intellectual property resulting from the R&D, or-Canco owns marketing rights in the intellectual property resulting from the R&D in Canada only under a cost-sharing agreement with USCo? ... TABLE RONDE SUR LA FISCALITÉ FÉDÉRALE APFF- CONGRÈS 2005 Question 7 Crédits R & D et sous-traitance La société Usco exploite une entreprise exclusivement aux États-unis où son actionnaire unique réside. ... Canco n'est associée à aucune autre société et elle verse annuellement 450 000 $ en salaires. ...

STEP CRA Roundtable – June 13, 2017 QUESTION 5. Allocation of safe income to discretionary dividend shares At the 2016 CTF Annual Conference, the CRA indicated that it was conducting a study of how safe income on hand should be allocated for corporations that have issued shares that are entitled to discretionary dividends, and when a dividend disproportionate to the respective pro rata interest is declared on such shares. ...

Reasons: See below. 2020 STEP CRA Roundtable – November 26, 2020 QUESTION 16. ...

Raisons: Pursuant to international agreements, disclosure of such information is not permitted. 2021 International Fiscal Association Conference CRA Roundtable Question 6 – Arbitration Can the CRA give any statistics on the number of cases that have been brought to arbitration under each of our tax treaties that include arbitration provisions? ...

Reasons: Based on a textual, contextual and purposive analysis. 2015 International Fiscal Association Conference CRA Roundtable Question 4 – Upstream loans: subsection 90(9) deduction Part A Assume the following: Canco directly owns all the shares of FA, a foreign affiliate; In 2013 FA made a US$100 loan (Loan 1) to Canco; FA's currency for surplus purposes is the US$ and at the "lending time" in 2013 FA had exempt surplus and net surplus of US$100; In 2014 FA paid a dividend (Dividend) of US$50 at a time when it had exempt surplus and net surplus of US$150 (no Reg. 5901(2)(b) election is made); Loan 1 is not repaid within two years; and Canco has nil adjusted cost base ("ACB") in the FA shares. ... In other words, the condition in the pre-amble of paragraph 5901(2)(b) – that requires that "in the absence of [that] paragraph" subsection 5901(1) would deem an amount to be paid out of exempt, hybrid or taxable surplus – would be met. ...