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7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 4, 2020-0851621C6 F- RRSP or RRIF on death – Joint election-- summary under Subsection 146(8.1) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(8.1) a specific bequest of a RRSP proceeds to a surviving spouse cannot be treated as a refund of premiums (a) Where an unmatured RRSP is the subject of a particular legacy to the deceased annuitant's spouse and the RRSP proceeds are distributed by the RRSP issuer directly to the surviving spouse, does the CRA require Form T2019 to be filed? ... Since the executor exercises the seisin of the legatee by particular title at the formation of the estate, in such a case, the amount paid under the deceased annuitant's RRSP is part of the annuitant’s estate, with the result that such an amount would not qualify as a "refund of premiums" within the meaning of subsection 146(1), even though the proceeds of the RRSP are paid by the issuer of the RRSP directly to the surviving spouse in accordance with the instructions of the executor. … Thus, as specified in subsection 146(8.1), the executor and the Spouse will have to file Form T2019 jointly if they wish to designate the amounts that the estate received (or, as the case may be, is considered to have received) from the deceased annuitant's RRSP as a refund of premiums received by the Spouse. ...

10 October 2024 APFF Roundtable Q. 11, 2024-1028921C6 F- Récupération d’amortissement liée à un bien de la catégorie 10.1 – travailleur autonome-- summary under Paragraph 13(7)(d) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(7)- Paragraph 13(7)(d) where a vehicle is used both personally and for business by a self-employed worker, there is a choice between a simplified method, and that under ss. 13(7)(c) and (d) CRA considers that the CCA deduction for the motor vehicle of a self-employed worker that is used for both business and personal use can be computed by determining the amount of CCA in respect of the motor vehicle as if it were used entirely for business purposes, while deducting annually only the proportion of CCA corresponding to the business use in the particular year. ... Since the cost to him of the passenger vehicle (a designated immediate expensing property per Reg. 1104(3.1)) was higher than the Reg. 7307(1) limit, s. 13(7)(i) provided that the proceeds of disposition were computed as: $38,000 X $34,000/ $50,000 = $25,840, resulting in recapture of depreciation. ...

8 December 2009 TEI Roundtable Q. 4, 2009-0347701C6- Qualifying person & multiple shares-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A The correspondent noted that in Canada, if each class of shares of a public company with multiple classes must be considered separately for purposes of satisfying the de minimis or 10-percent tests in the U.S. tax regulations (treated as being applicable for Canadian purposes under para. 2(c) of the "qualifying person definition) very few Canadian corporations with multiple classes of voting shares will be considered "qualifying persons" for purposes of the LOB clause. ...

3 June 2011 STEPs Roundtable Q. 2, 2011-0401831C6- 2011 STEP Conference-Q2-Trusts & Principal Res.-- summary under Subsection 107(4.1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(4.1) where a cottage is contributed to an inter vivos trust by a Canadian-resident individual (B) who is one of the beneficiaries, then the s. 107(2) rollover will be available if the cottage is distributed to B out of the trust (e.g., in advance of the 21-year deemed disposition date under s. 104(4), given that B will be "the person...from whom the particular trust...received the property); however, the rollover will be available if the cottage is distributed out to another capital beneficiary (D) at a time that the contributor (B) is still living as the quoted condition will be satisfied. ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4-- summary under Subsection 20(11) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(11) Art. ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4-- summary under Article 24 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 24 Art. 24(5) of US treaty a complete code for US citizens A U.S. citizen is required to pay U.S. tax on dividends and capital gains at a 20% rate (increased from the previous 15% rate). ...

28 November 2010 CTF Roundtable, 2013-0487431C6- Value of Vote-Only Shares – 2010 CTF Conference-- summary under Subsection 70(5) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(5) The questioner referenced the CRA statement at the 2009 British Columbia Tax Conference that, in the context of an estate freeze of a Canadian-controlled private corporation, where the freezor, as part of the estate freeze, keeps controlling non-participating preference shares in order to protect his economic interest in the corporation, CRA generally accepts that no premium should be attributed to such shares in determining their fair market value under s. 70(5), and asked whether this position also applies for the purposes of s. 104(4)(a), e.g., re the deemed disposition arising on the death of the spouse who is the beneficiary of a spousal trust. ...

10 October 2014 APFF Roundtable Q. 4, 2014-0534831C6 F- 2014 APFF Roundtable, Q. 4- Late-filed 86.1 election & 220(3.5) penalty-- summary under Subsection 86.1(2) Summary Under Tax Topics- Income Tax Act- Section 86.1- Subsection 86.1(2) general principles applied to relief of s. 86.1 late-election penalties Is the making of a late election generally accepted without application of the penalty of $100 per month if the absence of a timely election is attributable solely to ignorance of the availability of the election or of the occurrence of an eligible distribution? ...

11 October 2013 Roundtable, 2013-0499671C6 F- Actif d'impôts futurs / Future income tax assets-- summary under Subparagraph (c)(i) Summary Under Tax Topics- Income Tax Act- 101-110- Section 110.6- Subsection 110.6(1)- Qualified Small Business Corporation Share- Paragraph (c)- Subparagraph (c)(i) future income tax asset is not an asset/tax receivable can be used in an active business Is a future income tax asset an asset used in an active business for the purposes of the definition of QSBC definition? ...

9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 3, 2015-0588951C6 F- Deductibility of interest – ss. 20.1(1)-- summary under Paragraph 20(1)(c) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) no source disappearance where interest-free advance to sub is forgiven The sole shareholder of a CCPC uses borrowed funds to make an interest-free advance to the CCPC, and the CCPC then makes a proposal under the BIA, which is accepted by the creditors and entails the shareholder advance being cancelled. ...