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The CRA’s Guidance on the Common Reporting Standard states that a “person is treated as a beneficiary if … they receive, directly or indirectly, a discretionary distribution from the trust … in the calendar year....” ... Of particular interest is that the UK chapter of STEP, in collaboration with the OECD, posted a Guidance Note on the interpretation of what “settlor” means in the CRS rules: 1.3 … [T]here may be trusts in existence where an individual (X) acts as the named settlor of the trust and contributes a nominal amount on its creation but where another individual (Y) then makes the substantive contribution of assets to the trust. ...

. … As no amount is included in the computation of income under the provisions of the Act, no amount could be included as FAPI. ... Accordingly, the life insurance proceeds … would form part of Foreignco's pre-acquisition surplus pool. ...

11 October 2013 Roundtable, 2013-0495281C6 F- Question 9- APFF Round Table-- summary under Subsection 146.3(6.1) Summary Under Tax Topics- Income Tax Act- Section 146.3- Subsection 146.3(6.1) transfer of RRIF by executor to RRIF of surviving spouse Does the position in 2002-0141355- that an RRSP can be transferred to the RRSP of a surviving non-resident spouse, who can open an RRSP, even if he or she does not have a Social Insurance Number ("SIN") – apply to the transfer of an RRIF? CRA responded: [W]here an amount out of the RRIF of a deceased annuitant is paid to the deceased's legal representative and the surviving spouse is the beneficiary of the estate, subsection 146.3(6.1) deems the amount received by the legal representative of the last annuitant under the fund to be received by the surviving spouse to the extent that, on the one hand, the amount would have been a refund of premiums if it had been paid, under the plan, to the beneficiary spouse of the annuitant's estate and that, on the other hand, it is jointly designated by the legal representative and the surviving spouse in the prescribed T1090 form … filed with the Minister as required by the definition of "designated benefit" in subsection 146.3(1). ...

18 June 2015 STEP Roundtable Q. 11, 2015-0578551C6- 2015 STEP–Q11-Subsection 118.1(5.1)-sub property-- summary under Subsection 118.1(5.1) Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(5.1) share redemption proceeds – but not by a dividend – are substituted property Amended s. 118.1(5.1) require that a donation be a gift of "property that was acquired by the estate on and as a consequence of the death" or "property that was substituted for that property. ...

. … [T]he fact that inner door access is installed between the two units or that meals are prepared and taken the vast majority of the time in one of the two units does not appear to be sufficient for the two units to be considered as a single housing unit for the purposes of the I.T.A. ... On this basis, only the housing unit ordinarily inhabited by the individual qualifies as a principal residence. … Our comments would be the same if the property belonged to the parent, except that in this case, one or other of the housing units could qualify as the principal residence of the parent. ...

. … [I]f an employer establishes an arrangement under which it has full discretion to award a bonus or has full discretion as to the mode of payment of this bonus (in shares or in cash), [this] discretion… would ensure that it could not be an agreement for purposes of section 7…. ... This could be the case [where]…[a]fter the first year, the employer exercises its discretion and sets the amount of the bonus at 75 shares, which is payable in shares at the end of the year if the employee is still employed by the employer. … [T]he choice of the employee…does not preclude an undertaking from being an agreement to issue shares. ...

After discussing the s. 104(27) designation to preserve the character of such payment as being out of the RPP, CRA stated: Subsection 103(4) of the … ITR … provides for the withholding rates that apply where a payment is made in the form of a "lump sum payment" by an "employer" to an "employee". ...

In the case of disability of either individual, Opco will receive the proceeds of the policy covering such event in order to then pay a special dividend of $1,000,000 to the Holdco of the active shareholder to fund the purchase by the latter of the shares held directly by the disabled individual – with Opco then redeeming shares held by the purchased Holdco of the disabled individual for $500,000. After indicating that there was insufficient information to provide more than a general discussion of the purpose tests in ss. 55(2.1)(b)(i) and (ii), CRA noted that, in 2015-0613821C6, it indicated that it could issue a favourable advance ruling on a determination of purpose “where all manifestations of purpose and corroborating circumstances support the absence of one of the purposes described in subparagraph 55(2.1)(b)(ii) and (ii)” with such determination “conditional on the representation made by the taxpayer that the purposes for which the dividend was paid do not include one of the purposes described in proposed paragraph 55(2.1)(b)(i) and (ii) ….” ...

Can the estate designate itself as the graduated rate estate (“GRE”) of the deceased (non-resident) individual when filing its first tax return under Part I – and what is required respecting if there was no SIN? ... (d) of the GRE definition- that the estate designate itself as the GRE of the deceased individual in its Part I return for its first taxation year ending after 2015 – would be satisfied if such designation was made in the estate’s return for its first taxation year after 2015 in which it was required to file a Part I return. ...

CRA went on to note that it had not considered whether s. 248(1) – “disposition” – (f) or s. 107.4(3) could accord rollover treatment. ...