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Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 3. ... Iacobucci, J. later summarized, at paragraph 85, which documents or agreements are relevant to determining de jure or effective control of a corporation: (1) … (2) The general test for de jure control is that enunciated in Buckerfield's, supra: whether the majority shareholder enjoys "effective control" over the "affairs and fortunes" of the corporation, as manifested in "ownership of such a number of shares as carries with it the right to a majority of the votes in the election of the board of directors". (3) To determine whether such "effective control" exists, one must consider: (a) the corporation's governing statute; (b) the share register of the corporation; and (c) any specific or unique limitation on either the majority shareholder's power to control the election of the board or the board's power to manage the business and affairs of the company, as manifested in either: (i) the constating documents of the corporation; or (ii) any unanimous shareholder agreement. (4) Documents other than the share register, the constating documents, and any unanimous shareholder agreement are not generally to be considered for this purpose. (5) … Thus, an agreement that is not an unanimous shareholder agreement would not generally be considered in determining de jure control of the corporation. ...

Position: Yes Reasons: The CRA's position, as stated at the 2007 CTF CRA Roundtable, that paragraph 251(5)(b) should be applied on a "holder-by-holder basis," remains unchanged QUESTIONS PRESENTED AT THE 2011 CTF CRA ROUNDTABLE November 2011 Question # 11 Is the CRA continuing to maintain its position that paragraph 251(5)(b) denies a Canadian private corporation's Canadian-controlled private corporation ("CCPC") status if non-residents hold a sufficient number of options to have de jure control if only those options are exercised, notwithstanding that a sufficient number of options to preserve the corporation's CCPC status might also be held by Canadian residents? ...

Position: Yes Reasons: The interest rate is set at the time of the transfer of property. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 2. ...

STEP CRA Roundtable – June 18, 2015 Question 3. Redeemable Preferred Shares and subsection 18(4) The CRA has previously commented that it is the legal form of the particular financial instrument, not its economic substance, that will usually determine its income tax treatment. ...

Position: On hold Reasons: Waiting for outcome of appeals before the Tax Court of Canada TEI / CRA Liaison Meeting December 6, 2005 Q. 11- Subsection 95(6) and Tax Avoidance What is the status of the Draft Technical News on subsection 95(6)? ...

Apart from standard automated notifications to identify file and record level errors, no further information has been requested by the US in respect to this data. 2019 STEP CRA Roundtable – June 7, 2019 Question 17. ...

Reasons: Based on subsection 120.4(3). 2020 STEP CRA Roundtable – November 26, 2020 QUESTION 8. ...

Position: General comments provided Reasons: See below 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 15. ...

PROVINCIAL ROUNDTABLE – QUESTION 32 (2021-090510) Question 32 Loans to shareholders and the tax on split income (TOSI) A loan to a shareholder may result in an income inclusion (Subsection 15(2)) to a shareholder or connected person. ...

Position: Yes Reasons: 2017 amendments. 2022 STEP CRA Roundtable – June 15, 2022 Question 17. ...