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8 May 2012 Roundtable, 2012-0435771C6- CALU CRA Roundtable – May 2012- Question 10-- summary under Subsection 207.6(2) Summary Under Tax Topics- Excise Tax Act- Section 207.6- Subsection 207.6(2) In response to a question as to the circumstances in which a life insurance policy can "reasonably be considered to be acquired to fund in whole or in part," CRA indicated that the factors it would consider would include: the identity of the employees whose lives are insured as compared to those to be provided benefits under the plan; the timing of the acquisition of the insurance and the setting up of the plan; the timing of the acquisition of the insurance and the setting up of the plan; reasons (other than the existence of the plan) for the employer's purchase of insurance. ...

22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution-- summary under Subsection 93(2.01) Summary Under Tax Topics- Income Tax Act- Section 93- Subsection 93(2.01) a contribution of FA1 shares to FA2 causes the FA2 shares to be substituted property for s. 93(2.01) purposes A wholly-owned foreign affiliate (“Luxco1”) of Canco held 1/3 of the shares of a corporation ("NRco") resident in a Treaty country. ...

4 August 2016 Internal T.I. 2016-0645521I7- 90(6) & sale of creditor affiliate-- summary under Subsection 90(14) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(14) deduction not dependent on FA being creditor affiliate at repayment time In 2013, FA, which is wholly-owned by Canco, makes a loan to SisterCo., which is wholly-owned by the non-resident parent of Canco (“Foreign Parent”). ...

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.7, 2016-0674811C6 F- Allocations automobiles & dépenses afférentes-- summary under Subsection 200(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 200- Subsection 200(3) correction of T4s In the context of a general discussion of the course of action to be followed where an employer subsequently determines that T4 slips issued by it were erroneous, CRA stated: Where an employer realizes that a mistake has been made, the employer must normally prepare modified T4 slips to correct the situation. ...

3 March 2017 Internal T.I. 2016-0673661I7- Upstream loans – allocation of repayments-- summary under Paragraph 90(8)(a) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(8)- Paragraph 90(8)(a) ordering of upstream loan repayments determined on FIFO basis Prior to August 19, 2011, Canco borrowed $50M (“Advance A”) from its wholly-owned non-resident subsidiary (“FA”), and borrowed a further $50M (“Advance B”) from FA under the same revolving credit facility in October 2012. ...

21 January 2009 External T.I. 2008-0266191E5 F- Part IV & Capital Gain Strip-- summary under Paragraph 55(2.1)(c) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) portion of the dividend received by the recipient corporation that is subject to Pt. ...

14 September 2017 Roundtable, 2017-0703921C6- 2017 CPA Alberta Q25: Estates – Income Paid or Payable-- summary under Subsection 104(6) Summary Under Tax Topics- Income Tax Act- 101-110- Section 104- Subsection 104(6) income of fixed-interest trust is not per se payable IT-286R2, para. 6 states that the income of the trust for that year is considered to be payable to the beneficiaries where the sole reason for the rights of a beneficiary being unenforceable is the existence of an executor's year, the taxation year of a testamentary trust coincides with the executor’s year, and all of the beneficiaries agree to this treatment. ...

2 May 2005 Internal T.I. 2005-0119971I7 F- CDA- Excessive Election & Late Filed Election-- summary under Subsection 83(3.1) Summary Under Tax Topics- Income Tax Act- Section 83- Subsection 83(3.1) where no s. 83(2) election filed for statute-barred year, CRA should request late election under s. 83(3.1) or, failing which, assess a taxable dividend under s. 184(4)(b)(ii) CRA never received a s. 83(2) election in respect of a dividend payable in 1997 by Yco to its sole shareholder, an individual ("Y"). ...

21 November 2017 CTF Roundtable Q. 1, 2017-0724301C6- 21 year planning & NR beneficiary-- summary under Subsection 107(5) Summary Under Tax Topics- Income Tax Act- 101-110- Section 107- Subsection 107(5) GAAR very well may apply to s. 107(2) distribution to Canco owned by NR beneficiary The beneficiaries of a Canadian resident discretionary family trust (the “Trust”) are individuals who are intended to receive the Trust’s property (not described in ss. 128.1(4)(b)(i) to (iii)) who had emigrated from Canada as well as one or more Canadian companies (“Canco”) that are wholly owned by one or more of such beneficiaries. ...

21 November 2017 CTF Roundtable Q. 11, 2017-0724081C6- ULC-LLC structures & Treaty-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 Treaty anti-hybrid rule (Art. 7(b)) rule applies to dividends paid by a ULC to two LLCs held by U.S. ...