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LLPs & LLLPs Classification-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 facts and circumstances test respecting transition of LLPs to corporation status At 2016 IFA Roundtable, Q. 1, CRA indicated it had finalized its view that Florida and Delaware limited liability partnerships and limited liability limited partnerships are corporations for ITA purposes, but indicated that it was prepared as an administrative matter to continue accepting that an existing LLP or LLLP (that had been formed from scratch rather than being converted from an LLC) is a partnership if it is clear that the members are carrying on business in common with a view to profit, all members and the LLP or LLLP having been treating it as a partnership for ITA purpose, and the LLP or LLLP converts to a “true” partnership before 2018. ...

8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10-- summary under Subsection 207.6(2) Summary Under Tax Topics- Excise Tax Act- Section 207.6- Subsection 207.6(2) In response to a question as to the circumstances in which a life insurance policy can "reasonably be considered to be acquired to fund in whole or in part," CRA indicated that the factors it would consider would include: the identity of the employees whose lives are insured as compared to those to be provided benefits under the plan; the timing of the acquisition of the insurance and the setting up of the plan; the timing of the acquisition of the insurance and the setting up of the plan; reasons (other than the existence of the plan) for the employer's purchase of insurance. ...

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.7, 2016-0674811C6 F- Allocations automobiles & dépenses afférentes-- summary under Subsection 200(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(3) correction of T4s In the context of a general discussion of the course of action to be followed where an employer subsequently determines that T4 slips issued by it were erroneous, CRA stated: Where an employer realizes that a mistake has been made, the employer must normally prepare modified T4 slips to correct the situation. ...

14 September 2017 Roundtable, 2017-0703921C6- 2017 CPA Alberta Q25: Estates – Income Paid or Payable-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) income of fixed-interest trust is not per se payable IT-286R2, para. 6 states that the income of the trust for that year is considered to be payable to the beneficiaries where the sole reason for the rights of a beneficiary being unenforceable is the existence of an executor's year, the taxation year of a testamentary trust coincides with the executor’s year, and all of the beneficiaries agree to this treatment. ...

21 November 2017 CTF Roundtable Q. 1, 2017-0724301C6- 21 year planning & NR beneficiary-- summary under Subsection 107(5) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(5) GAAR very well may apply to s. 107(2) distribution to Canco owned by NR beneficiary The beneficiaries of a Canadian resident discretionary family trust (the “Trust”) are individuals who are intended to receive the Trust’s property (not described in ss. 128.1(4)(b)(i) to (iii)) who had emigrated from Canada as well as one or more Canadian companies (“Canco”) that are wholly owned by one or more of such beneficiaries. ...

21 November 2017 CTF Roundtable Q. 11, 2017-0724081C6- ULC-LLC structures & Treaty-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Treaty anti-hybrid rule (Art. 7(b)) rule applies to dividends paid by a ULC to two LLCs held by U.S. ...

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 5, 2017-0707801C6 F- RRIF transfers – partition of family patrimony-- summary under Subsection 146.3(14) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(14) amount paid to surviving spouse's RRIF did not qualify under s. 146.3(14) A couple separated in 2010 without proceeding to an official division of their assets. ...

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 5, 2017-0707801C6 F- RRIF transfers – partition of family patrimony-- summary under Paragraph 60(l) Summary Under Tax Topics- Income Tax Act- Section 60- Paragraph 60(l) transfer from deceased's RRIF to RRIF of surviving spouse in settlement of claim A couple separated without proceeding to an official division of their assets. ...

29 May 2018 STEP Roundtable Q. 6, 2018-0743971C6- Excluded Shares – Holding Company-- summary under Excluded Shares Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares holding company shares do not qualify as excluded shares In general terms, is it possible for shares of a holding company to qualify as "excluded shares"? ...

5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F- entreprise exploitée activement – revenu de location-- summary under Active Business Carried On by a Corporation Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Active Business Carried On by a Corporation question of fact whether a CCPC with too many employees to have a specified investment business carries on a business Realtyco is a CCPC holding in Canada six buildings each containing 50 residential units, which it rents out. ...