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9 October 2015 APFF Roundtable Q. 20, 2015-0595681C6 F- Avantages imposables / dépenses d’entreprise-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) employer-provided parties, bike stands and internal recreation areas generally not taxable benefits It is "the CRA’s position is that when an employer offers free-of-charge, to all employees, a party or other social event, there is no taxable benefit if the cost per party or other social event does not exceed $100 per person. ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c)-- summary under Subsection 85.1(3) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(3) drop-down of FA shares to non-share FA deemed to be for share consideration S. 95(2)(c) which, insofar as relevant to the question of how it dovetails with s. 93.2, is essentially identical to s. 85.1(3). ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election-- summary under Subsection 104(14) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(14) preferred beneficiary election and qualified disability trust election potentially can coexist Each of four grandparents of a disabled grandchild establishes a trust for the grandchild individual under their will, with one of the trusts being intended to be a qualified disability trust (“QDT”). ...

7 October 2016 APFF Roundtable Q. 11, 2016-0652941C6 F- Contrat de location / Capital lease-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation FMV of rights under a lease must be included Is the asset recorded in the financial statements as a capital lease considered as an asset used in an active business for purposes of the definitions of a qualified small business corporation share or of a small business corporation? ...

29 November 2016 CTF Roundtable Q. 1, 2016-0669301C6- GAAR & 21-year rule planning-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) avoidance of 21-year rule through 107(2) transfer to corporate beneficiary A discretionary resident trust that is approaching its 21st anniversary distributes property with an unrealized gain to a corporate beneficiary that is wholly owned by a newly-established discretionary trust. ...

6 October 2017 APFF Roundtable Q. 1, 2017-0708971C6 F- Inactive Corporations & subs. 162(7) ITA-- summary under Paragraph 150(1)(a) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1)- Paragraph 150(1)(a) requirement for Canco to file nil T2 returns, but no penalty What was the CRA position on: (a) the obligation of an inactive Canadian corporation to file a T2 return for each of the years in which there is no business activity and, thus, no tax payable; and (b) the application of late-filing penalties? ...

5 October 2018 APFF Roundtable Q. 17, 2018-0768881C6 F- entreprise exploitée activement – revenu de location-- summary under Specified Investment Business Summary Under Tax Topics- Income Tax Act- Section 125- Subsection 125(7)- Specified Investment Business principal purpose means main or chief objective In the course of a general discussion as to whether a Canadian-controlled private corporation with rental properties carried on an active business, CRA stated (before referring to the more-than-five full time employee test): A "specified investment business" is essentially a business, including a business of leasing real or immovable property, the principal purpose of which is to derive income from property, including rents. ...

27 November 2018 CTF Roundtable Q. 13, 2018-0779991C6- 20(1)(c) & Triangular Amalgamation-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by parent for use in connection with a triangular amalgamation to redeem preferred shares issued by Target can be deductible In a triangular amalgamation, is the interest on a third party loan obtained by ParentCo to redeem preferred shares issued by TargetCo as part of the transaction deductible under s. 20(1)(c)? ...

15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6- 78(1)(b)(ii) deemed loan & thin capitalization-- summary under Subparagraph 78(1)(b)(ii) Summary Under Tax Topics- Income Tax Act- Section 78- Subsection 78(1)- Paragraph 78(1)(b)- Subparagraph 78(1)(b)(ii) deemed s. 78(1)(b)(ii) loan is not also deemed to bear interest The thin cap rules apply to “outstanding debts to specified non-residents”, whose definition specifies that there is deductible interest paid or payable on them. ...

7 June 2019 STEP Roundtable Q. 7, 2019-0798321C6- Income Author / Musician-- summary under Income or Loss Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(4)- Income or Loss royalty income was incident to composing active business Gagliese Productions found that a company which earned royalties from the daily activities of its sole shareholder and employee in writing and producing music for TV episodes was earning income from an active business rather than from a specified investment business. ...