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25 September 2012 CTF Roundtable Q. 4, 2012-0457581C6- CTF BC – Q4 Residency of a Trust Principal Issues: Impact on the CRA published position in relation to the factors it considers indicative for purposes of establishing residency of a trust in light of the 2012 SCC decision in St. ... Reasons: Comments as previously published by the Directorate British Columbia Tax Conference September 25, 2012 Question 4 – Residency of a Trust for Tax Purposes CRA's long-standing position on the determination of the residency of a trust for tax purposes is described in IT-447 Residence of a Trust or Estate (published in 1980). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c) CRA Tags 93.2 Principal Issues: Whether paragraph 95(2)(c) applies in a situation where a taxpayer transfers shares of a foreign affiliate to another foreign affiliate that is a “non-resident corporation without share capital”, within the meaning of subsection 93.2(1), without any “shares” being issued as consideration? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 10 – Interaction of section 93.2 and paragraph 95(2)(c) It is our understanding that subsection 93.2(3) was introduced with the specific purpose of facilitating the application of paragraph 95(2)(c), among other provisions, to “non-resident corporations without share capital”, within the meaning of subsection 93.2(1). ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election CRA Tags 108(1) Principal Issues: 1. ... STEP CRA Roundtable – June 10, 2016 Question 4. Qualified Disability Trust and Preferred Beneficiary Election There are a number of conditions that must be met in order for a trust to be eligible to be a Qualified Disability Trust (“QDT”) for a particular tax year. ...

7 June 2019 STEP Roundtable Q. 4, 2019-0799911C6- TOSI & Meaning of Excluded Business Unedited CRA Tags 120.4 Principal Issues: Whether dividend income earned by a spouse who works as a part-time receptionist in the business would be subject to TOSI. ... Reasons: See below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 4. ...

8 July 2020 CALU Roundtable Q. 3, 2020-0842151C6- Insurance Proceeds & CDA Unedited CRA Tags "capital dividend account" defn in ss. 89(1); s. 148; ss. 248(1), Reg. 306, Reg.1401(3) Principal Issues: Whether the "fund value" portion of a payment made under an exempt single-life life insurance policy by an insurer to a corporation as a consequence of the death of the life insured under the policy is "proceeds of life insurance" for purposes of subparagraph (d)(ii) of the definition of capital dividend account in subsection 89(1). ... The scheme of these rules generally provide for the taxation of amounts received by a policyholder out of the policy prior to the death of the life insured under the policy, but on a tax-free basis where they are paid out as a consequence of the death of the life insured. 2020 CALU CRA Roundtable – July 2020 Question 3- Proceeds of an Insurance Policy and Calculation of the CDA credit Background One of the death benefit patterns permitted under a Universal Life (UL) policy is often referred to as “face amount plus fund value”. ...

5 May 2021 IFA Roundtable Q. 3, 2021-0888281C6- IFA 2021 Q.3: 247(3)- C$5 M Threshold & 261(5) Unedited CRA Tags 247(3), 261(5)(b), 261(5)(c). ... Reasons: Interpretation of the Act. 2021 International Fiscal Association Conference CRA Roundtable Question 3 – Application of subsection 261(5) to the $5M threshold of subsection 247(3) Assume that a Canadian corporation (“Canco”) with an “elected functional currency”, within the meaning of subsection 261(1), is subject to “transfer pricing income adjustments”, as defined in subsection 247(1), in respect of a “functional currency year”, as per the meaning of that expression under subsection 261(1). ...

17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Unedited CRA Tags Article XXX(3) of the Canada-Barbados Treaty Principal Issues: Under the Insurance Act (Barbados), a Class 2 licence entitles the company to insure third-party risks wherever situated. ... Reasons: See below. 2023 IFA Annual Conference CRA Roundtable Question 4- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Paragraph 3 of Article XXX (Miscellaneous Rules) of the Canada-Barbados Income Tax Convention (“the Treaty”) provides: 3. ...

15 September 2020 IFA Roundtable Q. 6, 2020-0853561C6- Subsection 212.3(9) & The GAAR Unedited CRA Tags 18(4), 212(2), 212.3(9), 245(2). ... Reasons: See below. 2020 International Fiscal Association Conference CRA Roundtable Question 6 – Subsection 212.3(9) and The GAAR At all relevant times, a non-resident corporation owns all the common shares of a corporation resident in Canada (Canco), which shares are the only issued and outstanding shares of Canco. ...

8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10 Unedited CRA Tags 207.6(2) Principal Issues: 1) What factors does the CRA consider in determining whether the RCA deeming rule in subsection 207.6(2) applies to a particular life insurance policy? ... CALU CRA Roundtable – May 2012 Question 10- Deemed RCA Rules Background Subsection 207.6(2) of the Act deems the RCA rules to apply to situations where 1) the employer has a legal obligation to provide benefits that are to be received or enjoyed by any person on, after, or in contemplation of any substantial change in services rendered by the retirement or loss of an office or employment of a taxpayer; 2) the employer acquires an interest in a life insurance policy; and 3) such insurance policy “may reasonably be considered to be acquired to fund, in whole or in part,” the benefits. ...

7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician Principal Issues: Question 7 of the 2019 Step Conference. 1. ... Reasons: Our previous position. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 7. ...