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27 June 2016 External T.I. 2016-0637341E5 F- Partnerships- Negative ACB-- summary under Subsection 40(3.1) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.1) loans by LP to partner potentially gave rise to negative ACB gain Rather than making current distributions of its cash flow to a limited partner, those sums are lent by the LP to the limited partner – then at the beginning of the following year the LP effects a distribution of the applicable share of the previous year’s profits to the limited partner by issuing a demand note to it and pays that note by way of set-off against the loans owing by the limited partner. ...

. … The fact that property was received from the Vendor in a fair market value purchase will not be relevant... ...

. … MFDA..or…AMF…), only the fund manager would be required to file T5008 slips with the CRA and provide a copy of the T5008 slip to the client. ...

Opinion S. 104(4) will not apply to the New Trusts by reason of (g) of s. 108(1) – trust. ...

.” … [I]t could nevertheless be established that…as with Hélie Holdco, BuyCo incurred no economic risk in participating in the transaction, did not derive any benefit from the purchase of shares, had no interest other than to allow the employee/shareholder to realize a capital gain and benefit from the deduction, and had no function independent of the employee /shareholder or the operating corporation- and, in short, it only participated in the transaction as an accommodation for the benefit of the employee/shareholder. ...

. … [I]f under civil law or common law, as applicable, partner A did not obtain a loan nor become the debtor of the partnership or of partner B by reason of distributions in favour of partner A under the partnership agreement, the conditions for the application of subsection 15(2)…would not be satisfied. ...

7 October 2016 APFF Roundtable Q. 1B, 2016-0652761C6 F- T4A filing-- summary under Subsection 200(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(1) no expanded relief from the broad T4A reporting requirements In light of the wording of ITA s. 153(1)(g) and Reg. 200(2), there is a broad range of inappropriate circumstances where the issuance of a T4A is required – for, example, where a corporation pays an amount greater than $500 to its accountant for professional services. ...

. … Regarding the February 22, 1994 election, the CRA still considers as valid the form, Election to Report a Capital Gain on Property Owned at the End February 22, 1994, filed by a taxpayer in accordance with the instructions and information available at that time. ...

7 October 2016 APFF Roundtable Q. 2, 2016-0652841C6 F- Changement partiel d’usage- immeuble locatif et résidentiel-- summary under Principal Residence Summary Under Tax Topics- Income Tax Act- Section 54- Principal Residence triplex contained separate housing units An individual owner of the whole triplex used Unit 1 (representing 50% of the area) for direct personal use and rented out the other two units – then some years later (at the beginning of “Year 11”), started renting out Unit 1, moved into Unit 2 for direct personal use and provided Unit 3 to family members at a low rent. ...

. … Accordingly, since Mr. died before having completed the transfer of the capital property, that transfer instead was effected by his estate, which is a trust and does not comply with the requirements of subsection 73(1). ...