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10 October 2024 APFF Financial Strategies and Instruments Roundtable Q. 6, 2024-1023301C6 F- CELIAPP- Séparation / FHSA- Separation-- summary under Subsection 146.6(7) Summary Under Tax Topics- Income Tax Act- Section 146.6- Subsection 146.6(7) s. 146.6(7) does not override the requirement for the transferee (ex-)spouse to be a “qualifying individual” Can an individual who does not have a FHSA and who does not qualify as a “qualifying individual” at the time of the transfer as a result of a relationship breakdown described in s. 146.6(7)(a)(ii) open a FHSA to receive the transfer from the individual’s spouse's or former spouse's FHSA? ...

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 Class 10.1 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 10.1 choice between technical and simplified method where mixed business and personal use 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. ...

11 December 2024 External T.I. 2024-1039101E5 F- Vertical amalgamation & former paragraph 84.1(2)(e)-- summary under Paragraph 87(2)(j.6) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(2)- Paragraph 87(2)(j.6) s. 87(2)(j.6) does not apply for purposes of the “old” s. 84.1(2)(e) intergenerational transfer rules S. 84.1(2.3)(a)(i), as part of the former (private-member bill) intergenerational business transfer rules, provided that if, otherwise than by reason of death, the children’s purchaser corporation disposed of the subject corporation shares within 60 months of their purchase, the exception in s. 84.1(2)(e) from the application of s. 84.1 was nullified. 2022-0953991E5 indicated that, consequently, if the purchaser corporation amalgamated, within the 60-month period, with the subject corporation, then the resulting disposition pursuant to s. 87(11)(a) of the subject shares engaged the s. 84.1(2.3)(a)(i) exclusion. ...

20 June 2023 STEP Roundtable Q. 3, 2023-0968091C6- Trust Reporting – Definition of Money and Treatment of Dividend Receivable-- summary under Subparagraph 150(1.2)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(b)- Subparagraph 150(1.2)(b)(i) gold or silver bar or coin would not qualify as “money”/ dividend receivable not included in “shares” Pursuant to s. 150(1.2)(b), the exception from trust reporting requirements under s. 150(1.1)- that may be available to individuals with no Part I tax payable or relevant dispositions- can apply to a trust for a particular tax year where the trust holds assets restricted to listed types of property including “money,” with an FMV not exceeding $50,000 throughout the year. ...

17 January 2025 Internal T.I. 2024-1029791I7 F- SSUC- Rémunération de la haute direction / CEWS--- summary under Executive Remuneration Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(1)- Executive Remuneration no adjustments are made to an eligible entity's Statement of Executive Compensation for NEOs filed pursuant to NI 51-102 for CEWS repayment purposes The Directorate found that the “executive remuneration” (as defined in para. ...

17 January 2025 Internal T.I. 2024-1029791I7 F- SSUC- Rémunération de la haute direction / CEWS--- summary under Subsection 125.7(14) Summary Under Tax Topics- Income Tax Act- Section 125.7- Subsection 125.7(14) repayment based on NI 51-102 statements, without adjustments Ss. 125.7(14) and (14.1) could require exchange-listed eligible entities to repay all or part of the CEWS they had received based inter alia on the excess of their executive remuneration over the 2019 base level. ...

& Section 116116(5)-- summary under Subsection 116(5) Summary Under Tax Topics- Income Tax Act- Section 116- Subsection 116(5) no acquisition of property by the obligor corporation when its debt repaid or employee stock option exercised S.49(3) did not apply to deem the exercise of employee stock options held by a non-resident former employee to not be a disposition of the options, given that s. 49(3) applied only to capital property, whereas employee stock options are governed by s. 7. ...

18 March 2003 External T.I. 2003-0002915 F- Subsections 40(3.3) & 40(3.4)-- summary under Subsection 40(3.4) Summary Under Tax Topics- Income Tax Act- Section 40- Subsection 40(3.4) taxpayer can designate order of disposition On December 16, 2002, Holdco sold 200 of its 1,000 common shares of a public corporation to an unaffiliated person $1,500, realizing a capital loss of $500, and less than 10 days after December 16, 2002, Holdco acquired 200 new common shares of the public corporation at a cost of $1,500. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11)-- summary under Subsection 87(11) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(11) survivor style amalgamation on Code reverse triangular merger Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. ...

2012 Ruling 2010-0355941R3- reverse subsidiary merger- 87(1) & 87(11)-- summary under Subsection 87(1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1) reverse triangular "E" merger- survivor style amalgamation Under a BC plan of arrangement, a BC corporation ("SubcoTarget") is merged with its wholly-owned BC subsidiary ("Target") to form "Amalco" with the same effect as if they had amalgamated under section 269 of the Business Corporations Act (BC), except that the legal existence of Target does not cease and it survives the merger, Subco ceases to exist and the property of Subco (other than its shares of Target, which are cancelled) become the property of Target. ...