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. … We suggest you make a submission to the Department of Finance. ...

CRA noted that this was similar to Example 9 of CRA’s split-income guidelines, and stated that they both could be considered to be actively engaged in the business – but indicated that this was a question of fact. ...

CRA indicated that there is no requirement that the replacement property be acquired after the former property is disposed of – so that the acquisition of the new property in advance of the disposition of the former property would not prevent it from being a replacement property for ss. 13(4.1) and 44(5) purposes. ...

3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 8, 2023-0976901C6 F- RPP survivor benefit flowing through a GRE-- summary under Subsection 104(24) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(24) income can be distributed to estate beneficiary by issuing a demand note to her CRA indicated that s. 104(24) would be satisfied regarding the distribution by an estate of a pension benefit received by it to the sole beneficiary (the surviving spouse) through the estate issuing a demand note to her “to the extent that the issuance of the note was permitted by the will and … the demand note was unconditional.” ...

4 June 2024 STEP Roundtable Q. 14, 2024-1011571C6- T3 Trust Instalments-- summary under Subsection 156(1) Summary Under Tax Topics- Income Tax Act- Section 156- Subsection 156(1) no change to administrative practice of not charging interest or penalties for insufficient instalment payments by trusts CRA indicated that its release of two new forms- the T3 INNS3, Trust Instalment Voucher and the T3AO, Trust Amount Owing Remittance Voucher – does not signify any change to its current administrative practice of not charging interest or penalties for insufficient instalment payments by trusts. ...

It is difficult to see how the current results obtained using pipelines do not invoke the same policy concerns that other non-arm’s length transfers do – for example, the inter vivos 84.1 transfers that are more explicitly covered in the changes to s. 84.1(2)(a.1). ...

. … [S]ubsection 94(10) will deem Mr. X to have made the contribution to Trust at a time other than a non-resident time for each taxation year commencing with the taxation year during which Mr. ... Z, a previous long term resident of Canada, became a non-resident in January 2007, in July 2010 made a contribution to a non-resident trust (the "Trust2") and in March 2015, became a resident of Canada – and that Trust2 has Canadian resident beneficiaries who are not successor beneficiaries. ...

In the situation where FA1 was required to compute its income (pursuant to Reg. 5907(1) – earnings – (a)(iii)) under Part I of the Act, CRA indicated that the interest was deductible under s. 20(1)(c) “because the borrowed funds replaced capital that…had been used by FA1 for the purpose of earning income from an active business,” whereas in the situation where the earnings were computed pursuant to (a)(i) or (iii) of the earnings definition under local tax law and the interest was non-deductible under such law, CRA simply stated that the interest would be deductible under Reg. 5907(2)(j). ...

. … The onus is on the taxpayer to provide support for the calculation of safe income that can reasonably be viewed as contributing to the capital gain on a share. The CRA expects the supporting documentation to be organized as an accumulation of year-by-year computations. … …[W]here…the taxpayer offers an alternative proxy such as the accounting retained earnings or adjusted retained earnings balance…the CRA auditor might conclude that retained earnings is a fair proxy for safe income on hand but only after a very stringent validation process. ...

Each is a question of fact …. … Paragraph 3 of IT-459 mentions that although an adventure or concern in the nature of trade is included in the definition of the term "business" in section 248 of the Act, it does not necessarily mean that a taxpayer who is engaged in an adventure or concern in the nature of trade is "carrying on" a business or has "carried on" a business. ...