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4 June 2024 STEP Roundtable Q. 9, 2024-1020351C6- Paragraph 150(1.2)(b) and GICs-- summary under Paragraph 150(1.2)(b) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2)- Paragraph 150(1.2)(b) holding any GIC would preclude a trust from qualifying under s. 150(1.2)(b) CRA indicated that a GIC issued by a Canadian bank or trust company did not constitute one of the assets listed in s. 150(1.2)(b), such as money, or a government issued or guaranteed debt obligation described in s. 212(3) – fully exempt interest – (a). ...

. … IT-422, [para. 2] … provides that in order for an asset to be a tool, it must be designed to create a physical change in something or be used as an instrument of measurement or manipulation. … In addition, paragraph 8(6.1)(d) of the Act specifically excludes electronic communication devices as eligible tools. Therefore, the cost of an aviation headset would not be deductible under paragraph 8(1)(s), or any other provision …. ...

Where such a general partner is a wholly-owned subsidiary of the sole limited partner, it is possible that the limited partner has " de facto " control over the limited partnership, or that the general partner is in a relationship of subordination to the limited partner, in which event the limited partner would not deal at arm's length with the limited partnership (unless Regulation 1102(20) applied). ...

However, in order to meet the test in clause 95(2)(a)(i)(B) … it would … be necessary to establish that if the funds on which the interest was earned had been held by Manco, such funds would be employed or at risk in the business of Manco (i.e. not excess funds). ...

. … [Such] refund … is an amount covered by paragraph 12(1)(x), but that paragraph will not apply if the refund amount has already been included in the taxpayer's income or has already reduced the expense in accordance with accepted commercial principles. ...

. … [Such] refund … is an amount covered by paragraph 12(1)(x), but that paragraph will not apply if the refund amount has already been included in the taxpayer's income or has already reduced the expense in accordance with accepted commercial principles. ...

29 February 2024 Internal T.I. 2023-0987941I7- Amendments to GAAR and Advance Income Tax Rulings-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) CRA after the GAAR amendments will continue to rule on post-mortem pipelines complying with its published policies, but not on inter vivos surplus stripping by individuals Regarding the status of post-mortem pipeline transactions following the amended GAAR rule, the Directorate stated: The Directorate does not consider the use of a pipeline transaction as a means to preserve the capital gain arising on the death of a shareholder while limiting double taxation on the subsequent distribution of Opco’s assets to be a … [GAAR] abuse …. ...

29 February 2024 Internal T.I. 2023-0987941I7- Amendments to GAAR and Advance Income Tax Rulings-- summary under Subsection 245(4) Summary Under Tax Topics- Income Tax Act- Section 245- Subsection 245(4) CRA will continue to issue post-mortem pipeline rulings following the GAAR amendments, but will not rule on surplus stripping by individuals Regarding the status of post-mortem pipeline transactions following the amended GAAR rule, the Directorate stated: The Directorate does not consider the use of a pipeline transaction as a means to preserve the capital gain arising on the death of a shareholder while limiting double taxation on the subsequent distribution of Opco’s assets to be a … [GAAR] abuse …. ...

CRA responded: In general terms, the determination of whether an obligation has been disposed of for Canadian income tax purposes depends on whether these events are considered to result in the discharge of the obligation and the substitution of a new obligation under the law governing the former obligation …. Where the governing law is Canadian … making a RFR Amendment to an IBOR Instrument to accommodate the transition from IBOR to RFRs, in and of itself, would generally not constitute a disposition of the IBOR Instrument …. Where foreign law governs an obligation … the legal effect of these events on such an obligation under the relevant foreign law must be considered in order to determine if the obligation has been disposed of …. ...

CRA responded: [S]ubsection 89(8) is technically applicable …. [R]esponsibility for tax policy … rests with the Department of Finance ….” ...