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28 September 2023 CLHIA Roundtable Q. 1, 2023-0971701C6- Life insurance – contractual changes Unedited CRA Tags 148(10)(d) Principal Issues: Does the endorsement to a defined set of policyholders of a benefit under an in-force exempt life insurance policy for no cost and no underwriting requirement constitute a disposition for tax purposes? ... CLHIA Roundtable – September 28, 2023 Question 1 – Life Insurance and contractual changes Background Insurers often include new benefits when designing products that were not available for previously issued policies (access to health advocate services, return of premium for certain situations, coverages for previously excluded activities, etc.). ...

15 May 2019 IFA Roundtable Q. 3, 2019-0798741C6- Participating Debt Interest & US Treaty Unedited CRA Tags 212(1)(b)(ii), 212(3) “participating debt interest”; Art. ... Under the Canada-US Tax Convention (the “Treaty”) however, interest paid by a resident of Canada to a resident of the United States that is entitled to the benefits of the Treaty is not subject to Canadian withholding tax, other than interest: “arising in Canada that is determined with reference to receipts, sales, income, profits or other cash flow of the debtor (…), to any change in the value of any property of the debtor (…) or to any dividend, partnership distribution or similar payment made by the debtor...” ... Yannick Roulier / Nicolas Bilodeau 2019-079874 May 15, 2019 ...

18 June 2015 STEP Roundtable Q. 8, 2015-0581961C6- 2015 STEP – Q8- Foreign entity classification Principal Issues: Does CRA keep a list of foreign entities that it generally considers to be trusts. ... STEP CRA Roundtable – June 18, 2015 Question 8. Foreign Entity Classification The case of Sommerer highlighted the need for practitioners to carefully consider the issue of foreign entity classification when dealing with foreign legal entities / relationships. ...

26 May 2016 IFA Roundtable Q. 2, 2016-0642061C6- AOA & Notional Expenses CRA Tags Treaties Article VII Principal Issues: Whether notional expenses determined under the AOA and attributable to a taxpayer’s permanent establishment in Canada can be deducted for Canadian tax purposes? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 2 – Authorized OECD Approach to Profit Attribution The possibility of deducting notional expenses in determining the profits attributable to a permanent establishment (“PE”) of a non-resident under Canada’s tax treaties was seemingly put to bed by the 1998 decision of the Federal Court of Appeal in Cudd Pressure (footnote 1). ... In respect of the Canada – United Kingdom Tax Convention, we would note that the new AOA-based Article 7 language was included in the convention by virtue of the protocol signed on July 21, 2014. ...

STEP CRA Roundtable – June 18, 2015 Question 14. Requirements for Question #6 on page 2 of the T3 Return Question 6 of the T3 return reads as follows: Did the trust borrow money, or incur a debt, in a non-arm's length transaction since June 18, 1971? ... The instructions for question 6 refer the reader to Interpretation Bulletin IT-406R2 – Tax Payable by an Inter Vivos Trust (the "IT"). ... Reference may be made to Folio S1-F5-C1 – Related persons and dealing at arm's length, for discussion as to the meaning of the term "at arm's length". ...

LLPs & LLLPs CRA Tags 248(1) "corporation" Principal Issues: Whether LLPs and LLLPs governed by the laws of Florida or Delaware would generally be treated as corporations for the purposes of the Act? ... Reasons: The provisions of the foreign legislation and the articles creating these entities support the general conclusion that these types of entities should generally be treated as corporations for the purposes of the Act. 2016 International Fiscal Association Conference CRA Roundtable Question 1 – Entity Classification: U.S. ... The main factors we considered in our analysis of these entities are the existence of a separate legal personality that is recognized under the law of the relevant foreign jurisdiction – meaning the full legal capacity to acquire and own property, to sue and be sued, to carry on their own activities and to incur liabilities of their own – and the extensive limitation of liability afforded to all of their members. ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4 CRA Tags Treaties Article XXIV 126(7) "non-business-income tax" 20(11) Treaties Article V Principal Issues: What credits and deductions are available to U.S. citizens resident in Canada on taxes paid in respect of dividend income now that rates have increased in conjunction with the "fiscal cliff". ... Reasons: Text of the treaty. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 4. ...

10 June 2013 Roundtable, 2013-0480411C6- STEP Roundtable – June 2013- Question 10 Principal Issues: Deductibility of probate and related fees by an estate. Position: Question of fact Reasons: In our view, the Tax Court of Canada's decision under the informal procedure was based on the unique facts of the case. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 10. ...

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution CRA Tags 93(2) 93(2.01) Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to shares owned by a taxpayer in respect of which the taxpayer made a capital contribution consisting of shares of another foreign affiliate? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 7 – Subsection 93(2.01) substituted property rule and capital contributions Assume the following hypothetical facts: a) Canco owns all of the shares of each of FA1 and FA2. b) Canco capitalizes FA1 with $1,000 of equity. c) FA1 loans $1,000 to FA2 for use in its active business. d) A few years later, after having paid dividends of $50 to Canco, FA1 becomes a wholly-owned subsidiary of FA2 as a result of a contribution of capital by Canco of the shares of FA1 to FA2. ...

13 February 2017 Roundtable, 2017-0684491C6- CPA-BC & CRA Roundtable 2017 Principal Issues: Whether the CRA will re-introduce a dedicated phone line for tax professionals. ... CPA-BC & CRA Roundtable 2017 Question 16: We were very excited about the introduction of the CRA’s “professional designated phone line”, only to find out that this was meant for small practitioners who have no tax advisers. ...