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BEPS Actions 8-10 (revised transfer pricing guidelines) The working party responsible for Actions 8-10 (“Working Party Six”) was the only BEPS party to operate on a consensus basis; that is, the soft language in those Actions was essentially by design – e.g. using “may” instead of “shall.” ... We have held off until now because the financial transactions project is not finalized – there may be some big changes coming out of that. ... We do not necessarily see that as the case – our penalty regime is based on reasonable efforts. ...

Email this Content 2020 IFA-YIN Seminar on COVID-19 Guidelines Q.1 — Whether "Travel Restrictions" Must Be Enforceable Q.2 — Meaning of "Solely as a Result" Q.3 — Individual Not Ordinarily Resident in Canada Q.4 — Non-Resident Employers Q.5 — Directors Forced to Stay in Canada Q.6 — Location of Board Meetings Q.7 — Applicability to Residence in Other Jurisdictions Q.8 — Competent Authority Tie-Breaker Rule Q.9 — Non-Treaty Countries Q.10 — Non-resident corporation's return obligation Q.11 — S. 253(b) test during COVID Q.12 — TPM-17 and COVID government assistance Q.13 — Contacting CRA Q.14 — Waiver and Clearance Certificates Q.15 — CEWS and bad debts/discounts Q.16 — Convertible debentures Q.17 — Cameco This summarizes CRA responses at a webinar hosted by the International Fiscal Association (Canadian Branch) on 6 August 2020 (a Young Members Event). ... Would the presence of an employee in Canada — with or without the approval of their employer — be a situation in which the employer is considered to be carrying on business in Canada pursuant to paragraph 253(b) of the ITA? ... Q.16 — Convertible debentures Is there any update on the CRA’s administrative position on convertible debt as expressed in 2013-0509061C6 Part XIII Tax & Standard Convertible Debentures? ...

Delayed interpretation requests and related assessments Question CRA Response Q.30- Non-residents and permanent establishments Facts / Background Questions CRA Response Q.31- Update on audit issues and discussion Question CRA Response GST/HST audits and examinations enhancements Pre-assessment reviews Recaptured Input Tax Credits Q.32- Update on court cases/objection and discussion Facts/Background Question CRA Response Supplementary Questions Q.1- Treatment of general partner distributions Facts / Background Question CRA Response Q.2- Section 259 of the Excise Tax Act Facts / Background Questions CRA Response Q.3- HST- Conferences Facts / Background Questions CRA Response Q. 4 and 5 Supplies of Admissions Supplies of Real Property (i.e., Booth Space) Supplies of Other Personal Property and Services (e.g., Related Convention Supplies) Sponsorships of Events Q.6 and 7 Q.8 Q.4- RRSP’S / RRIF’S / RESP’S and the SLFI regulations Facts/Background CRA Response Q.5- Incorrect accounting for HST versus QST Facts / Background Questions CRA Response Q.6- Master trusts and the new pension rules Question CRA Response Q.7- Pension plan rules – deemed supplies – provincial factor- contribution – regular and special payment Facts/Background Question CRA Response Q.8- Calcualtion of the SAM – Hybrid pension plans Question CRA Response Q.9- Public sector body pension plans and the HST deemed supply rules Question A-1 Question A- 2 CRA Response A-1 CRA Response A- 2 Question B-1 Charity and public institution CRA Response Question B – 1 Charity Question B – 2 Charity CRA Response B- 2 Charity Question B – 3 Charity: CRA Response B – 3 Charity Question B – 1 Public Institution CRA Response B-1 Public Institution Question B – 2 Public Institution CRA Response B – 2 Public Institution Question B – 3 Public Institution CRA Response B – 3 Public Institution DISCLAIMER These comments do not replace the law found in the Excise Tax Act (the Act) and its Regulations. ... Q.6- Place of supply rules – section 182 damage payments Facts / Background A Co and B Co are both resident in Canada and registered for GST/HST purposes. ... Q.21- Residency of investment vehicles (LPs AND trusts) & zero-rating of investment management services Facts / Background Services that are supplied to a non-resident are generally zero-rated. ...

Email this Content 26 November 2013 Annual CTF Roundtable Q. 1 ("Pre-ruling consultations") Notes from Presentation Q. 2 ("Upstream loans") Q. 2(a) – Repayment of upstream loans Notes from Presentation Official Response Q. 2(b)(i) – Repayment of upstream loans – Back-to-back loans Notes from Presentation Summary of Written Response Official Response Q. 2(b)(ii) – Repayment of upstream loans – Back-to-back loans Notes from Presentation Summary of Written Response Official Response Q. 3 ("CAE Inc. ... Q. 4(b) – T1135/T1134 – No e-filing/ T1135-extension of normal reassessment period Notes from Presentation Electronic filing of T1134s and T1135s has not yet arrived. ... The obligations — much like needed repairs to property — are a future cost embedded in the forest tenure that serves to depress the tenure’s value at the time of sale. ...

Email this Content 26 February 2009 CBA Roundtable Q.1- Lease Subsidy Payments By Non-Resident Manufacturer To Canadian Lessor Facts / Background Question Reasons in Support of Zero-Rating CRA Comments Q.2- Constructive Importer Rules And Section 180 Exclusion Facts / Background Question CRA Comments Q.3- Assignment Of Employment Contracts & Reverse Payment Facts / Background Question CRA Comments Q.4- Wash Transaction Assessment That Is Subsequently Overturned Facts / Background Question CRA Comments Step 1. ... Credit Note / Refund to customers Alternative Reassessment Waiver of Interest Q.5- Section 167 Election On Dissolution Of Partnership Facts / Background Question CRA Comments Q.6- Drop Shipment/Gst Memoranda Series 3.3.1 Q.7- Zero-Rating Of Financial Services Facts / Background Question CRA Comments Q.8- Gst Registration & T2 Returns Facts / Background Question Q.9- Special Investigation Facts / Background Question CRA Comments Q.10- Bad Debts Facts / Background Question CRA Comments Q.11- Gst Treatment Of Payments On Behalf Of Co-Owners Facts / Background Question CRA Comments Q.12- Section 186 Input Tax Credit Entitlement Facts / Background Question CRA Comments Q.13- Deemed Financial Institution Facts / Background Question Discussion CRA Comments Q.14- Dealing With Taxpayer Representatives Facts / Background Question CRA Comments Facts / Background Question CRA Comments Q.15- S. 167- Availability Of Election. ... Rental Use Facts / Background Question CRA Comments Q.28- Electronic Coupons, Points, And The Meaning Of “Fixed Dollar Amount” Facts / Background Questions CRA Comments Q.29- Section 144.01 Of The Excise Tax Act Facts / Background Question CRA Comments Q.30- Rebate Documentary Requirements Facts / Background Questions CRA Comments Q.31- Reporting Gst On Residential Real Estate Transactions – Interplay Between Eta Section 194 And Subsection 221(2) Facts / Background Questions CRA Comments Q.32- Retroactive Deregistration Facts / Background Question CRA Comments Q.33- Subsection 182(1) Facts / Background Question CRA Comments Q.34- Canadian Supplier Facts / Background Question CRA Comments Q.35- Gst Registration Procedures Facts / Background Question CRA Comments Q.36- Eta 169(4) Documentation Facts / Background Question CRA Comments Q.37- Documentation To Justify The Transfert Price Facts / Background Question Facts / Background Question CRA Comments Q.38- Canadian Auctioneer Facts / Background Questions CRA Comments Q.39- Emphyteusis Facts / Background Question 1 CRA Comments Question 2 CRA Comments Q.40- Update By Appeals Branch CRA Comments 41. ...

SECTION 156 ELECTION Q.11- Use of a Newco – Section 156 Election Reply Q.12- Section 156 and Permanent Establishments Reply Q.13- Section 156 Election – Input Tax Credit Claims Reply Q.14- Section 156 and Partnerships Reply D. ... DROP-SHIPMENT RULES Q.36- Drop-Shipments – Subsection 179(4) Reply Q.37- Drop-Shipments – Leasing Arrangement Reply Q.38- Drop Shipments Rules – Interplay with Real Property Law Principles of Affixation Reply Q.39- Drop-Shipments – Carrying on Business Reply Scenario 1 Scenario 2 I. ... Financing Part A When – if at all – would a “financing lease” be considered a “loan” (i.e., exempt financial service) for GST purposes? ...

Email this Content 25 November 2021 CTF Roundtable Q.1 – Indemnities and Subsection 87(4) Preliminary Response Scenario 1 Scenario 2 Scenario 3 Scenario 4 Official Response Q.2 – Subsection 15(2) Shareholder Loans and TOSI Preliminary Response Official Response Q.3 – Section 86.1 Preliminary Response Official Response Q.4 – “Liable to Tax” and Territorial Taxation Preliminary Response Official Response Q.5 – Corporate Attribution in a Tiered Corporate Structure Preliminary Response Official Response Q.6 – Subsection 143.4(1) and the “right to reduce” Preliminary Response Official Response Q.7 – Sub-funds and the Tracking Interest Rules Preliminary Response Scenario 1 Scenario 2 Official Response Q.8 – Loan from a FA to a Partnership held by two FAs Preliminary Response Official Response Q.9 – Work-Space-in-the-Home Expenses Preliminary Response Official Response Q.10 – Regulation 100(4)(a) and Payroll Deductions and Remittances Preliminary Response Official Response Q.11-Subsection 261(21), Loan to FA and Excluded Property Preliminary Response Official Response Q.12 – Remission Orders and Fees Preliminary Response Official Response Q.13 – Income Tax Rulings Directorate Preliminary Response Official Response Q.14 – Failure to Properly File a T1135 and Section 233. ... S. 95(8) always turns on the pool of property – referred to as the “tracked property and activities.” ... The courts have also found that there must be a link between the money that was borrowed and the current use – the “current use approach.” ...

Email this Content 29 May 2018 STEP Roundtable Q.1 — Update on the Dedicated Telephone Service Preliminary Response Official response Q.2 — Creation of a Trust Preliminary Response Official response Q.3 — Trust return due date in the year of wind up Preliminary Response Official response Q.4 — Safe Income and an Estate Preliminary Response Official response Q.5 — Split Income Proposals- Definitions Preliminary Response Official response Q.6 — Split Income Proposals- Holding company qualifying as "excluded share" Preliminary Response Official response Q.7 — Split Income Proposals- Excluded shares and business income Preliminary Response Official response Q.8 — Subsection 70(5) Preliminary Response Official response Q.9 — Requirements for a trust to have all interests in the trust vest indefeasibly Preliminary Response Official response Q.10 — Pipeline Rulings Preliminary Response Official response Q.11 — Trusts subject to subsection 104(13.4) in year of death of the trust's primary beneficiary Preliminary Response Official response Q.12 — U.S. ... The test in proposed s. 120.4(1) – “excluded shares” – (a)(i) is that business income be less than 90% from the provision of services. ... Preliminary Response Phil Kohnen: In s. 108(1) – “trust” – (g), there is an exception to, among other things, the 21-year deemed disposition rule in s. 104(4). ...

Email this Content 21 November 2017 CTF Annual Conference Roundtable Q.1 – S. 107(2) distribution by resident trust to Canco owned by non-resident Preliminary response Official response Q.2 – Trusts and principal residence exemption Preliminary response Official response Q.3 – S. 55(2.1) “purpose” CRA response- Background Q.3(a) Purpose v. result Preliminary response Q.3(b) Objective v. subjective Preliminary response Official response Q.4 – S. 55(2) – Timing of deemed capital gain Q.4(a) Timing of gain Q.4(b) CDA Preliminary response Official response Q.5 – Interaction of ss. 55(5)(f) and 55(2.3) with s. 55(2.1) Q.5(a) Separate test Preliminary response Q.5(b) Stock dividend Preliminary response Official response Q.6 – Circular Pt. IV/55(2) calculations Preliminary response Official response Q.7 – CRA Folios update Preliminary response Official response Q.8 – MLI “principal purpose test” Q.8(a) GAAR Committee Preliminary response Q.8(b) PPT/GAAR Preliminary response Q.8(c) GAAR jurisprudence Preliminary response Q.8(d) OECD examples Preliminary response Official response Q.9 – Stock option deduction Preliminary response Official response Q.10 – Tax shelter rulings Preliminary response Official response Q.11 – Application of Art. ... This is not a new position – I refer you to 2012-0440191R3. Official response 21 November 2017 CTF Roundtable Q. 10, 2017-0724291C6- Tax Shelters Q.11 – Application of Art. ...

ELECTIONS Q.10- Late-filed Section 167 Elections CCRA Comments Q.11- Section 167 Election – Impact of Amalgamation CCRA Comments Q.12- Section 167 Election – Interpretation Facts Question CCRA Comments Q.13- Joint Venture Elections – Bare Trusts CCRA Comments D. ... OTHER Q.37- Fruit Juices CCRA Comments Q.38- Telecommunication Services – Fibreoptic Cable CCRA Comments Dark Fibre Lit Fibre Dim Fibre Q.39- New Housing Rebate – 254(2)(e) – Title Taken in Different Name CCRA Comments Q.40- Capital Property – All or Nothing Approach CCRA Comments Q.41- “Hot” Audit Issues and Current Cases CCRA Comments Q.42- Business Numbers CCRA Comments Amalgamations Partnerships Q.43- Closely Related Persons CCRA Comments A. ... Q.39- New Housing Rebate – 254(2)(e) – Title Taken in Different Name Is the new housing rebate under s. 254 available if title is taken in the name of a person other than the one who signed the Agreement of Purchase and Sale as purchaser? ...