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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). ...

Similarly, the definition of "principal residence" in section 54 states that it is a residence “owned, whether jointly with another person or otherwise, … by the taxpayer”. ...

Trevor McGowan – The idea is that the hallmarks in s. 237.3 would be essentially unchanged – confidentiality, premium or contingent fees, and contractual protections. ... Tax loss consolidation Shawn Porter – Moving then to tax loss consolidation. ... Group Ratio Shawn Porter – Not every country has adopted a group ratio. ...

Email this Content Finance Comfort Letters 2019 Link Affected legislation Principal topics Dec 2 Cross-Border Surplus Stripping & Graduated Rate Estates s. 212.1(6)(b) exception to s. 212.1(6)(b) look-through rule for graduated rate estates Sept 4 Principal Residence Exemption for Trusts s. 54 – principal residence – (c.1)(iii.1)(B) extend “principal residence” status for QDTs where an inter vivos trust Sept 3 Deductibility of Mining Taxes s. 20(1)(v), Reg. 3900(2), s. 152(4) removal of statute-barring where increase in mining taxes Aug 26 “Advantage”: Exclusion for Investment Management Fees “Advantage”: Exclusion for Investment Management Fees s. 207.01(1) definition of "advantage" and investment management fees of registered plans July 29 Eligible Capital Property (ECP) Transitional Issue s. 14(1) eligible capital amount recognition grandfathering of deferred proceeds from ECP disposition July 29 Functional currency tax reporting- currency of Japan s. 261(1) definition of ‘qualifying currency” designation of yen as qualifying currency 2018 Link Affected legislation Principal topics May 11 Saskatchewan Pension Plan- Tax Treatment of Variable Benefit Portion s. 146(21) et seq. variable benefits paid out of specified pension plan to qualify re pension income credits and income splitting and subject to Reg. 8506 May 1 repayment of back-to-back loans under the upstream loan rules s. 90(14) deemed B2B loan repayment deemed repayment of deemed loan under s. 90(7) similarly to ss. 15(2.18) and (2.19) 2016 Link Affected legislation Principal topics Dec 3 Foreign accrual property income resulting from the application of paragraph 95(2)(b) of the Income Tax Act to inter-affiliate payments for services s. 95(2)(b)(i)(B)(I) base erosion rule proposed extension of s. 95(2)(a)(ii)(D) safe harbor to inter-FA fees that are deemed FAPI under s. 95(2)(b)(i)(B)(I) 2015 Link Affected legislation Principal topics Nov 16 Spousal, alter ego and similar trusts s. 104(13.4) beneficiary income inclusion s. 104(13.4)(b) not to apply unless joint election joint election by trust and graduated rate estate and deceased died before 2017 – trust allocation of post death donations to s. 104(13.4)(a) year 2014 Link Affected legislation Principal topics Dec 23 The recent LRE amendments s. 251.2 loss restriction events s. 251.2(3)(f) safe harbour for unit redemptions – due date extensions for trust short year- loss restriction event only where actual beneficiary change [see also 2014-0534841C6 F]- application dates ...

However, we identified a number of issues – some of which were not borne out by the data and have been dropped. ... As noted in the paper, the intention was not do all of the proposals – indeed, some of them were mutually exclusive. ... The Greenhouse Gas Pollution Pricing Act – famously “not a tax” – has a preamble. ...

GAAR Consultation He noted that the August 9 GAAR consultation paper stated at its outset that Finance thinks the GAAR is working reasonably well – but, even so, it could do with a tune-up after more than 30 years of practice, experience, tax administration and case law. ... Although the paper sought to cover the possible proposals in a balanced manner, even being transparent where a possibility was perhaps not workable or necessary, some of the proposals still prompted strong reactions – all of which is an expected and useful part of the consultation process. ... Although the judicially developed analytical framework is reasonably sound, there are some cases that may benefit from a further statutory “nudge” with regard to economic substance – and the case was made for this benefiting the efficiency of the system overall. ...

Its structure differs in some respects from the rest of the MLI – it is a single cohesive arbitration provision and it does not have compatibility clauses with respect to each article. ... We learned quickly, when discussing that among European and other colleagues, that that does not mean much to them – they are not very familiar with salary arbitration in North America. ... Independent opinion is based on a precedent from the EU Arbitration Convention, and it would effectively work more like a court proceeding – with evidence rules and oral hearings. ...

We are also plugged into Dunn & Bradstreet data, and have an iteration of Watson as an appliance running in the background. ... How do transfer pricing audits work – how do they work in Canada, and how do they work internationally? ... The program cannot work without that – it is something we lost, and we need to put it back in the system. ...