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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 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. ...

Official response 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 5, 2017-0707801C6 F- RRIF transfers – partition of family patrimony Q.6 Treatment of RRIF balance where survivor spouse dies before transfer On the death of Mr. ... The total charitable gifts are based on the "eligible amount … of a gift". ... Official response 6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 16, 2017-0705181C6 F- Hedging & George Weston Limited ...

In Situations 1 and 2, were the survivor payments and "exempt contributions," as defined in s. 207.01(1) (the "Definition") $90,000 and $100,000, respectively – and what about Situations 3 and 4? ... Official Response 11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 8, 2019-0811901C6 F- RRIF – Minimum amount after death Q.9 Whether deemed payment under RRIF is pension income Is a “payment received” from a RRIF considered to be a “payment out of or under” a RRIF for purposes of the definition of “pension income” in s. 118(7). ...

Porter & Son Ltd. v. Minister of Finance (Nova Scotia) [1979] 5802 ETC (NSSC): owner of a crane provided by it with operator was the person using the crane; and Cairns Construction [1960] S.C.R. 619: builder was the person using building materials in the course of completing real property contracts)? ... The example cited from GST/HST Memorandum 19.2.3, Residential Real Property — Deemed Supplies, reflects the CRA’s current position on the interpretation of subparagraph 7(a)(i) of Part I of Schedule V to the ETA. ... Therefore, if legal ownership is not transferred to the particular individual with whom the builder entered into the agreement of purchase and sale – which seems to be the case in the situation described, as ownership of the new house seems to be transferred to the corporation as bare trustee – then the requirement in paragraph 254(2)(e) of the ETA is not satisfied and the Minister cannot pay a new housing rebate under subsection 254(2). ...