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. … Generally, we would consider 60 days to be a reasonable period of time for the employer to terminate the arrangement and pay the amounts to the employee. ...

25 November 2021 CTF Roundtable Q. 16, 2021-0911911C6- Convertible Debentures-- summary under Participating debt interest Summary Under Tax Topics- Income Tax Act- Section 212- Subsection 212(3)- Participating debt interest following Agnico-Eagle, CRA is reviewing whether the conversion of conventional convertible debentures gives rise to s. 214(7) interest When asked to provide an update on its views expressed in 2013-0509061C6 on whether convertible debentures give rise to participating debt interest that is subject to Part XIII tax, CRA indicated: Since then, CRA has only issued 2014-0532411R3 (making amendments and adding an opinion regarding 2011-0418721R3) and 2013-0514551R3. 2014-0532411R3 provided that any amount deemed by s. 214(7) to be interest on the note conversion would not be participating debt interest, and would not be subject to Part XIII withholding tax (assuming the arm’s length test was satisfied) – and provided an opinion that in the event of a disposition of the convertible note by a non-resident to a resident (other than the issuer) for cash proceeds, the amount deemed to be a payment of interest under s. 214(7) would not constitute participating debt interest. 2013-0514551R3 provided similar rulings, which were also applicable to make-whole amounts. ...

The estate will make a substantial distribution to Trust1, Trust2, Trust3 and Trust4 through a distribution of inter alia Notes1 to 4 now owing by Newco – with such Trusts agreeing with Newco to pay the accrued but unpaid interest owing by then on Trust-Note1 to 4 to Newco, by way of set-off against part of Notes1 to 4 owing to them by Newco. ...

However, if the interest at 5% was not a “reasonable return,” the split income amount would not be the total interest amount but, rather, only the excess over the reasonable return – so that, for example, if the reasonable return was 3%, the split income inclusion would be 2%. ...

CRA noted that no dividend refund arises to Opco on the $1,000,000 eligible dividend, so that there is no Part IV tax payable by Holdco thereon under s. 186(1)(b) – and that such dividend also is not subject to s. 55(2) as it does not exceed the $1,000,000 of safe income. ...

X’s will – which provided the same terms as described above. Here, since the shares held in the trust were not acquired by it as a consequence of Mr. ...

Consequently … it is possible that the conditions of subsection 104(18) could be satisfied in respect of the child or children of the deceased who are beneficiaries of the estate and who have not attained 21 years of age at the end of a particular taxation year. ...

Accordingly, the amendments “apply only to dispositions that occur on or after … June 29, 2021.” ...

It would make no difference if the house was co-owned by the two spouses (or if they were common-law partners) – rather than owned only by Mr. ...

The application of subsection 245(2) could be considered if the Pipeline Planning is structured to avoid the application of section 84.1 …. ...