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Where the CCPC claims a foreign tax deduction under subsection 126(1) ("FTD"), a reduction is provided for in the description of B of the formula “A – B” in subparagraph (a)(i) of the definition of NERDTOH. More specifically, the reduction is equal to the amount by which the CCPC's deduction for the year under subsection 126(1) (the “FTD”) in respect of its foreign non-business income (clause (A) of element B of the “A – B” formula) exceeds 8% of the foreign investment income ("FII") (clause (B) of element B of the “A – B” formula). ... This notional calculation of 8% of FII in clause (B) of element B of the “A – B” formula applies regardless of whether a foreign country has levied a tax on foreign source income. ...

Specifically, there were three things were identified in that Action plan: the master file, the local file, and – everybody’s favourite – the country-by-country reporting. ... There are other countries – the US in particular – that have not signed on to that. ... I think you’re right – the OECD and many others have said this is a risk-assessment tool – it is not a tool that will identify adjustments. ...

Email this Content Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar Preview of November 16, 2016 TCTSO CRA & Tax Professionals Group Seminar ...

There is nobody from the CRA on the Committee – it is just a working group of lawyers. ... Contemporaneous documents are usually going to be the most persuasive evidence you have – they are much better than someone’s recollection of whatever the tax plan was, years after the fact. ... We sometimes encounter documents that are worded very vaguely – asking us to fix the tax mistake and allowing the taxpayer to draft whole new documents, “whatever is needed.” ...

Email this Content 16 May 2018 IFA Finance Roundtable Q&A Q.1 – Update on Multilateral Instrument Response Q.2 – LOB and MLI Response Q.3 – Digitalization Response Q.4 – U.S. Tax Reform Response Q.5 – U.S. Repatriation Tax and U.S. Citizens Response Q.6 – US Interest Deductions and S. 95(2)(a)(ii) Response Q.7 – T1134 Filing Due Date Response Q.8 – Eligible Controlled Foreign Affiliates (ECFAs) Response Q.9 – Pertinent Loans and Indebtedness (PLOIs) Response Q.10 – Repayment of Back-to-Back Upstream Loans Response Comment on S. 15(1.4)(e) This summarizes the oral responses provided at the IFA Finance Roundtable held on May 16, 2018 at the Telus Centre in Calgary. ... We are always considering changes – that is what the consultation process is about. ...

Email this Content 26 April 2017 IFA Finance Roundtable- Official Response Question 1 – Interaction between subsections 17(1) and 247(2) CRA Response Scenario 1 Scenario 2 Question 2 – Application of section 247 in the computation of FAPI CRA Response Question 3 – U.S. LLPs & LLLPs CRA Response Question 4 – Subsections 261(20) / (21) and foreign affiliates CRA Response Question 5 – Foreign tax credit generator rules and Brazilian interest on equity CRA Response Question 6 – T1134 filing issues CRA Response Question 7 – Clause 95(2)(a)(ii)(D) issues regarding U.S. LLCs CRA Response Question 8 – NR4 reporting for non-taxable amounts CRA Response Question 9 – Computation of earnings for a disregarded U.S. ...

Howe, [1906] A.C. 455 (H.L.), at para. 458 12 This description was used in a UK decision, Laerstate BV v HM Revenue & Customs [UKFTT 09 (TC). Question 4: GAAR Committee Decision – Planning Involving the Intentional Use of Subsection 55(2) to Generate Capital Gains Consider the following scenario: Mr. ... Depuis le 1er janvier 2015, un régime est considéré comme un RPAM dans la mesure où « la totalité ou presque » des primes versées aux termes du régime se rapportent à des frais médicaux qui seraient par ailleurs admissibles au CIFM (en supposant que soient remplies toutes les autres conditions d’admissibilité pour un RPAM). ...

Email this Content 24 November 2015 Annual CTF Roundtable Q1: T2 Late-Filing: Dividend Refund & RDTOH Oral Response Official response Q2: Salary deferral arrangement rules (a) [RSU conversion to DSU] Oral Response Official Response Supp. ... We have received one good submission, which for us is surprising, as we did ask for submissions – so that we don’t know whether people aren’t concerned about it, or just haven’t encountered it (which I would find surprising). ... Official response 24 November 2015 CTF Roundtable Q. 9, 2015-0610561C6- s. 95(2)(a)(ii)(D)(IV)(2) Q10: Thin Cap & Foreign Currency Debt Non-resident parent makes a U.S. dominated loan to its Canadian subsidiary. ...

Trusts and Estates – Recent Legislative Changes [no response] This question was not addressed by the CRA. ... CRA Response Answer – (References are included below): As with any scenario, it depends on all of the facts. ... University & Public College Meal Plans [no response] This question was not addressed by the CRA. ...

Official Response 26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution 8) Borrowing to return capital and s. 95(2)(a)(ii)(B) A Canadian corporation (“ Canco ”) owns all the shares of a foreign affiliate (“ FA1 ”) which in turn owns all the shares of another foreign affiliate (“ FA2 ”). Canco also owns all the shares of another foreign affiliate (“ FA3 ”). ... The CRIC did not make timely pertinent loan or indebtedness (“ PLOI ”) elections. ...