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However … if an individual is not the owner or tenant of a self-contained domestic establishment (or the co-owner or co-tenant) but pays the expenses of the self-contained domestic establishment on a regular basis because of the individual’s responsibility for the establishment, we are generally of the view that the individual maintains a self-contained domestic establishment. ...

Respecting the second question, CRA stated that the “Manual used … [in] audits of small and medium-sized businesses does not contain any information on the application of subsection 55(2) and the purpose test, in particular.” ...

In the case of a limited partnership … it is usually the general partner that can exercise these rights. ...

., drawn on a bank account not belonging to the annuitant) – and, if so, whom should the receipt be issued to? ...

4 December 2018 TEI Roundtable Q. 1, 2018-0782341C6- Regulation 1103(1)-- summary under Subsection 1103(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 1103- Subsection 1103(1) Reg. 1103(1) election does not affect subsequent years’ acquisitions Folio S3-F4-C1, para. 1.132 states: [U[nder [Reg.] 1103(1) …, a taxpayer may elect to transfer all properties otherwise included in Classes 2 through 12 (excluding Class 10.1) to Class 1 provided that all such properties were acquired for the purpose of gaining or producing income from the same business. ...

For instance, in Year X4, the income of Investco was tainted because in its last taxation year (X3) it had received dividend income from Opco and, in any event, the taxable capital gain realized by it in that year was deemed by s. 120.4(1.1)(d)(i)(B) to be income derived from the Opco business. ­­­­­­­­­­­­­­­ ...

CRA indicated that the payments made during the 3 years likely qualified as gifts, as they were made at the discretion of the trustees – in which case, a donation tax credit could be claimed. ...

CRA indicated, likely “no” since once the estate administration was completed (or should have been completed), there would be no estate income (as the beneficial ownership of its property had passed to the residuary beneficiary) – or if the estate somehow were viewed as still earning income, such income would be payable to the beneficiary and, therefore, be income of the beneficiary under ss. 101(24) and 104(13) rather than of the estate. ...

12 September 2019 External T.I. 2019-0802301E5- Annuity purchased from foreign pension-- summary under Subsection 147.4(1) Summary Under Tax Topics- Income Tax Act- Section 147.4- Subsection 147.4(1) s. 147.4(1) permits non-inclusion where annuity is purchased out of RPP Before noting that s. 147.4(1) does not apply to annuities purchased from foreign pension plans, so that a retiree- whose former non-resident employer determined to wind-up a foreign pension plan by using funds in the plan to purchase annuity contracts for each retired member – was required under s. 56(1)(a)(i) to include the full fair market value of the annuity in income in the wind-up year, CRA stated: Where the conditions in subsection 147.4(1) are met, the individual is deemed not to have received an amount from the RPP as a result of acquiring the annuity and any amounts received under the contract are deemed to be amounts received under the RPP. ...

11 October 2019 APFF Financial Strategies and Instruments Roundtable Q. 6, 2019-0813451C6 F- TFSA- Bequest and disclaimer-- summary under Paragraph 248(8)(b) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(8)- Paragraph 248(8)(b) transfer of TFSA to survivor on renunciation of bequest thereof occurred as a consequence of death Although an individual made a specific bequest under his will of his TFSA to his adult daughter, she executed a written renunciation of the bequest (that CRA went on to find was deemed by s. 248(9) to result in a “disclaimer” or a “release or surrender” for purposes of s. 248(8)(b),) so that following the TFSA's liquidation by the executor, the proceeds were instead transferred by the executor to the widow of the deceased – who then promptly contributed such proceeds to her own TFSA. ...