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Question 1: Meaning of “Habitual Abode” in Canadian Tax Treaties As you know, Canada’s extensive treaty network contains residency “tie-breaker” provisions – usually in Article IV:2 of most of the treaties. ... Question 9: Subsection 247(4) – Contemporaneous Documentation and COVID-19 Canada’s contemporaneous documentation (“CD”) rules in subsection 247(4) require the completion of CD meeting statutory requirements within six months of the end of the relevant taxation year, a shorter time limit than is found in the analogous rules of most of Canada’s G7 contemporaries (typically one year). ... To request this type of relief, a taxpayer has to complete Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties and Interest. ...

Email this Content 17 June 2025 STEP Roundtable- Official Response Q.1- Succession of Family Business CRA Response More than one Purchaser Corporation Shares of the Purchaser Corporation held by a Corporation or Trust Part 1 Part 2 Part 3 Continuous Control Q.2- Succession of Family Business CRA Response Q.3- Bare Trusts that Ceased to Exist in 2024 CRA Response Q.4- Preferred Beneficiary Election CRA Response Q.5- RDSP Financial Hardship Withdrawals CRA Response Part 1 Part 2 Part 3 Q.6- Section 116 Partial Distributions from an Estate Covering Multiple Taxation Years CRA Response Q.7- Subsection 70(6) and Testamentary Spousal Trust CRA Response Part 1 Part 2 Part 3 Part 4 Q.8- Subsection 70(6) and Vested Indefeasibly CRA Response Q.9- Flipped Property and Section 85 CRA Response Q.10- Principal Residence Exemption and Subsection 73(1) Transfer to a Life Interest Trust CRA Response Q.11- Acquisition of Control of a Corporation CRA Response Q.12- CRA Update on Subsection 55(2) and Safe Income – Where Are We Now? ... Q.12- CRA Update on Subsection 55(2) and Safe Income – Where Are We Now? ... ” [4] (the “Safe Income Paper”) presented at the 2023 CTF CRA Roundtable, when a corporation transfers assets as part of a reorganization (a “spin-out”) covered by paragraph 55(3)(a), safe income of the transferor corporation should be allocated to the transferee corporation pursuant to a proration based on the net cost amount of underlying assets transferred. ...

A owned two identical properties (two undivided 50% co-ownership interests), each with an ACB of $125,000 (($100,000 + $150,000) / 2). ... "property [...] that is [...] a housing unit", restrict the scope of the measure to a property that is a single housing unit. ... However, that amount cannot be transferred to the annuitant's RRSP. 19 CANADA REVENUE AGENCY, Form T2030, " Direct Transfer Under Subparagraph 60(l)(v)" ("Form T2030") 20 Schedule 7, " Part A- RRSP, PRPP and SPP contributions " ("Part A") 21 Schedule 7, " Part C- RRSP deduction " ("Part C") 22 Schedule 7, " Part D- Unused RRSP contributions available to carry forward " ("Part D") 23 This information is indicated in Part 4 of Form T2030 24 CANADA REVENUE AGENCY, Form T1206, " Tax On Split Income- 2024 " 25 CANADA REVENUE AGENCY, Guide T4013, " T3- Trust Guide 2024 ". 26 CANADA REVENUE AGENCY, T3 slip, " Summary of Trust Income Allocations and Designations " 27 [1999] 3 S.C.R. 622 29 CANADA REVENUE AGENCY, Interpretation Bulletin IT-218R, " Profits, capital gains and losses from the sale of real estate, including farmland and inherited land and conversion of real estate from capital property to inventory and vice versa " (archived), September 16, 1986 ("Interpretation Bulletin IT-218R"). 30 Interpretation Bulletin IT-459, supra, footnote 28 31 Interpretation Bulletin IT-218R, supra, footnote 29 32 These rental expenses are, within the meaning of the Income Tax Act, a "non-compliant amount", which is an expression defined in subsection 67.7(1). ...

Email this Content Joint Committee and other submissions 2025 2024 2023 2022 2020 2019 2018 2017 2016 2015 2014 2013 2012 2011 2010 2009 2008 2007 2006 Date Copy of submission re: Principal topics 2025 Sept 15 15 August 2025 legislative proposals and technical amendments EIFEL rules, purpose-built residential rentals, negative taxable income, foreign mergers, s. 149(13), s. 18.2(1) – EIFE,- ATI – D(b), s. 18.2(20). s. 126(4.7), s. 85.1(4)(a)(ii) and s. 85.1(4)(a)(ii)(B) Apr 15 Suggested technical amendments to current ITA provisions Proposed technical amendments to EIFEL rules re s. 78(1)(a), s. 80(2)(b), s. 18.2(1) – excluded entity – (c), s. 18.2(1) – tax-indifferent, s. 18.2(1) – adjusted taxable income – C – (a), s. 18.2(1) – excluded lease, share buyback tax s. 183.3(1) – substantive debt – (c), s. 183.3(2), related company butterfly s. 55(5)(e)(i), Pt. ... Canada, 2020 FCA 21, s. 212(1)(i), s. 214(15)(b), s. 56.4(1)- restrictive covenant, consent, commitment and standby fees, early exchange bonus June 11 CRA Guidance re COVID-19 impact on international transactions COVID-19, designated treaty country, Reg. 5907(1)- exempt earnings, a. 95(1) – investment business, permanent establishment, non-qualifying country, services PE, qualifying non-resident employee June 1 19 May 2020 draft Time Limits and Other Periods Act (COVID-19) s. 180(1), s. 152(4), s. 152(3.1), s. 37(11), s. 127(9)- investment tax credit- – para. ... /FTC generators-FAT/interest on refunds May 3 2010 Budget: Non-Resident Trusts and FIEs non-resident trusts/foreign investment entities April 21 IT Bulletins re archiving all IT Bulletins Feb. 15 Dec. 18, 2009 Foreign Affiliate Amendments f.a. elections/s. 93(1)/fill the hold/bump/design. treaty country/FAPLs & FAT 2009 Sept. 30 Declaration Process re Treaty Witholding Rates Part XIII/Declaration of Benefits/waiver of penalties and interest April 1 Québec Paper on Aggressive Tax Planning GAAR penalties/promoter penalties/disclosure requirements Jan. 7 NRTs and FIEs non-resident trusts and foreign investment entities 2008 Sept. 15 July 14, 2008 SIFT Amendments "excluded subsidiary entity"/SIFT partnerships/SIFT trusts July 15 Canada's System of International Taxation foreign debt/treaty shopping/active business income/NRTs & FIEs/base erosion rules/FAPI June 18 SIFT Conversions SIFT trusts/asset transfers/continuity of tax attributes June 4 Bill C-10 NRTs/dual-resident trusts Senate Standing Committee comfort letters/residence/NRTs & FIEs/94(1)- "exempt foreign trust" Jan. 24 Bill C-10 NRTs & FIEs Jan. 8 Fifth Protocol treaties: residence/dividends/employment income/limitations on benefits 2007 Dec. 4 SIFT Conversion debt rollover/SIFT partnerships Oct. 23 2007 Budget 20(1)(e)/18.2(3)(a)(ii)- "substituted property"/18.2(9), (10)/s. 95.2(f), (f.1)/93.1 June 1 Foreign Affiliate Amendments accounting burden May 7 International Fair Tax Initiative grandfathering/uncertainty March 7 Bill C-33 – Ss. 52(3)(a), 53(1)(b) CDA/dividends/PUB increases/contributed surplus Feb. 21 "Normal Growth" for Income Trusts SIFT conversions/ambiguities in Guidelines Jan. 31 Dec 21, 2006 SIFT amendments deemed dividends/"investment"/"business"/"non-portfolio earnings" & "non-portfolio property"/REITs/"real or immovable property" 2006 Dec. 4 Eligible Dividend Rules 89(14) Sept. 29 Outstanding Income Tax Proposals interest deductions/foreign investments/foreign affiliates/interest & penalty relief Jan. 30 July 18, 2005 Technical Amendments attached submissions not in document Jan. 27 November 17, 2005 NWMM- S. 143.3 attached submissions not in document Jan. 20 Feb. 27 2004 Foreign Affiliate Amendments foreign affiliate PUC/foreign PUC currency/hedging arrangement currency ...

Subsection 74.4(4) – Exception to the Purpose Test Subsection 74.4(4), which provides an exception to the Purpose Test in subsection 74.4(2), does not apply in this situation for the reasons set out below. ... The service standard for a Ruling is 90 business days commencing with the receipt of all information required from the client as outlined in Appendix A – Ruling Request Checklist of Information Circular IC 70-6R11, Advance Income Tax Rulings and Technical Interpretations[FN3: IC 70-6R11 Advance Income Tax Rulings and Technical Interpretations was published April 1, 2021.] ... Remission of the service fee will be granted when the Ruling is issued, or the Pre-ruling Consultation is completed, subsequent to its service target date, as set out in Appendix H – Remissions of IC 70-6. ...

Brief summary of oral response No – it’s applied on the property ensemble. ... For details on this subject, please see “Estate Donations- Deaths after 2015", Questions / Answers [http://www.cra-arc.gc.ca/gncy/bdgt/2014/qa14-eng.html] and "Estate Donations by Former Graduated Rate Estates", Questions / Answers, that are available on the website of the CRA. ... If the CRA considered that the dividend of $35,000 declared on the Class "A" shares in the capital stock of Opco was part of the FMV of the Class "A shares immediately before the dividend payment, the hypothetical FMV of the Class "A" shares held by HA is $80,100 ([($170,300- $35,000) / 3] + $35,000). ...

The Directorate worked closely with Rulings to put together some of those examples that were posted in July, and will continue working with them – practitioners have raised areas where further examples are needed. ... Scenario 6- Landscaping business sells sod Example 4 on CRA’s webpage entitled “ Tax on split income – Excluded shares ” holds that a cleaning business that spends 15% of its revenue on cleaning products is nevertheless engaged only in cleaning services, because the supply of cleaning products is incidental to the services. ... Consider a landscaping business, which generates income from cutting grass, fertilizing, and sodding – which entails buying grass. ...

CRA has applied the following formula in determining the amount of a superficial loss, or a suspended loss under s. 40(3.4): Deemed nil loss = (the lesser of S, P and B) / S x L where S = number of shares disposed of at that time P = number of shares acquired in the period from 30 days before to 30 days after the disposition B = number of shares remaining at the end of that period L = loss on disposition otherwise determined Consider the following examples: Hypothetical Situation 1 On March 15, 2022, an individual disposes of all of his shares (being 2,000) of ABC Pubco, and realizes a capital loss of $10,000. ... (" Audet ").] where the Federal Court concluded that the amount received for the endorsement of a note was received for a service. ... Would this satisfy the condition in s. 146.01(1) – regular eligible amount- para. ...

If you use the OECD principal amount to determine the rate, what principal amount do you use – the thin cap, or the OECD amount – to calculate the total interest deduction under s. 20(1)(c)? ... In general, though, I am a fan of APAs – get the facts on the table, and arrive at certainty, in a bilateral or even multilateral APA. ... MacLean: I think it is clear that, under the Income Tax Act, a non-resident is a “taxpayer” – although admittedly that is often irrelevant. ...

If you are still unhappy, that would be where Headquarters gets involved – you contact the relevant director – the Director of International Tax Division, Large Business Audit Division, or Abusive Tax Avoidance Division (i.e., the GAAR division), or me. ... Cameco Cameco, is under appeal – CRA is still running its transfer pricing audit program. ... It’s a challenge – when you are auditing, you don’t know what you don’t know. ...