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Reasons: Plain meaning of words, as well as various TCC and FCA positions and OECD Model Convention Commentary. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 15. Meaning of Habitual Abode in Canadian Tax Treaties As you know, Canada’s extensive treaty network contains residency “tie-breaker” provisions – usually in Article IV:2 of most of the treaties. ...

Position: Possibly. 2022 CTF Annual Tax Conference CRA Roundtable Question 8 – Capital Cost Allowance and Crypto-asset Mining Hardware Commercial crypto-asset mining operations often involve the use of several graphics processing units (“GPUs”) or application-specific integrated circuit (“ASIC”) miners to generate computing power (“hash power”). ... ASIC Miners ASIC miners, on the other hand, are designed and optimized to perform a single task – mining crypto-assets. ...

Position: Question of fact as to the nature of the debt; but the creditor may incur a loss on the forgiveness of debt, the loss would be generally subject to the stop loss rules in subparagraph 40(2)(g)(ii) Reasons: general comments and positions discussed STEP CRA Roundtable – June 2012 QUESTION 3 Where indebtedness is forgiven by Will, a loss could result for the creditor. ...

Position: No Reasons: The failure to notify the CRA of the existence of a price adjustment clause when filing a tax return will not, in and of itself, preclude the CRA from recognizing the effectiveness of a price adjustment clause 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 7. ...

STEP CRA Roundtable – June 10, 2016 Question 3. Distribution from Inter vivos Trust to Graduated Rate Estate Inter vivos trusts may be created with one of the beneficiaries being an individual’s estate. ...

STEP CRA Roundtable – June 10, 2016 Question 6. Trust Instalment Requirements and Interest In response to question 9 at the 2014 STEP Canada National Conference, the CRA noted that under its then current administrative practices, penalties and interest would not be assessed where an inter vivos trust failed to make sufficient instalment payments. ...

Reasons: See reasons below. 2016 Canadian Tax Foundation Annual Conference CRA Roundtable Question 3 – Agnico-Eagle Mines Decision The Federal Court of Appeal’s (“FCA”) decision in The Queen. v. ...

STEP CRA Roundtable – June 13, 2017 QUESTION 1. Paragraph (b) of the Definition of “Specified Corporate Income” The inclusion of paragraph (b) in the definition of specified corporate income (“an amount that the Minister determines to be reasonable in the circumstances”) in subsection 125(7) creates significant uncertainty in the application of the small business deduction rules. ...

Reasons: 55(2.1)(c) 2018 STEP CRA ROUNDTABLE – May 29, 2018 QUESTION 4: Safe Income and an Estate At the 2017 STEP Roundtable, CRA made the point that safe income of a corporation owned by a person that died did not flow through to the estate of that person. ...

Hybrid Partnerships (Rulings- International & Trusts Division) At the 2004 International Fiscal Association seminar in Montreal (the "IFA Seminar"), representatives from CRA stated that CRA is reviewing its position regarding the treatment of a partnership formed in Canada and its U.S. partners, when the Canadian partnership is treated as a corporation under the U.S. check-the-box rules. ...