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CLHIA Roundtable- May 2019 Question 3 – Third Party RRSP contributions Contribution rules relating to RRSPs are well understood. ...

Reasons: Consistent with previous positions. 2020 CALU Round Table – July 2020 Question 7- Valuation of Private Company Shares Background At the 2009 British Columbia tax conference the CRA stated: "...non-participating controlling shares have some value and may therefore bear a premium. ...

Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 5. ...

Reasons: See examples. 2020 STEP CRA Roundtable – November 26, 2020 Question 6: Impact of an Eligible Offset on a Disposition of a Capital Interest in a Personal Trust Where a personal trust distributes property to a Canadian resident beneficiary in satisfaction of the beneficiary’s capital interest in the trust, the capital beneficiary is considered to have disposed of their capital interest and subsections 107(1) and 107(2) will generally apply. ... It is important to note that the deemed ACB resulting from paragraph 107(1)(a) is only relevant for determining a capital gain – it is not used to determine whether or not a capital loss (footnote 9) results. ... Dawn Dannehl / Steve Fron November 26, 2020 2020-083999 FOOTNOTES Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead: 1 Subsection 108(1) defines an “eligible offset” of a taxpayer at any time in respect of all or part of the taxpayer’s capital interest in a trust to be the portion of any debt or obligation that is assumed by the taxpayer and that can reasonably be considered to be applicable to the property distributed at that time in satisfaction of the interest or part of the interest, as the case may be, if the distribution is conditional upon the assumption by the taxpayer of the portion of the debt or obligation. 2 Subsection 107(2) is subject to subsections 107(2.001), (2.002), and (4) to (5). 3 Unless expressly otherwise provided in the Act, paragraph 248(1)(b) defines “cost amount” to a taxpayer of any property at that time which is a capital property (other than depreciable property) of the taxpayer to be its adjusted cost base to the taxpayer at that time. ...

Reasons: Subsection 270(2) provides that the provisions of Part XIX of the ITA relate to the implementation of the Common Reporting Standard set out in the Standard for Automatic Exchange of Financial Account Information in Tax Matters approved by the Council of the OECD and, unless the context otherwise requires, these provisions are to be interpreted consistently with the Common Reporting Standard, as amended from time to time. 2022 Canadian Tax Foundation Conference CRA Roundtable Question 10- Common Reporting Standard – Trusts and The Meaning of “Controlling Persons” Assume that a trust is resident in Canada, is not a “reporting financial institution” (“RFI”), is a “passive non-financial entity” (“Passive NFE”), and has a “financial account” with an RFI (footnote 1). ... [OECD Response] Pursuant to Section VIII(C)(4), a Reportable Person will be treated as a beneficiary of a trust “if such Reportable Person [...] may receive, directly or indirectly, a discretionary distribution from the trust. ... In particular, paragraph 1.3- Example 3 of the STEP/OECD Guidance states as follows: “1.3 Example 3: ‘nominal’ and joint settlors – there may be trusts in existence where an individual (X) acts as the named settlor of the trust and contributes a nominal amount on its creation but where another individual (Y) then makes the substantive contribution of assets to the trust. ...

STEP CRA Roundtable – June 2014 QUESTION 8. Transfer of property by a personal trust to a beneficiary A Canadian-resident trust that meets the definition of a "personal trust" in subsection 248(1) of the Act holds property that has appreciated in value since its acquisition by the trust. ...

12 June 2012 Roundtable, 2012-0442991C6- 2012 STEP Question 12 Principal Issues: General comments regarding the audit of high net worth individuals Position: CPB provided general comments STEP CRA Roundtable – June 2012 QUESTION 12 Could the CRA comment on its progress to date with respect to its audit focus on high net worth individuals? ...

CLHIA 2015 Roundtable Question 2 – Interaction of 95(2)(a.1) and 138(2) Consider a case where a corporation (Canco) resident in Canada and its wholly-owned foreign affiliate (FA) each carry on a life insurance business.   ...

Paragraphe 40(3.4): Conclusion — Objet: Participations dans une société de personnes Question 8 Lorsqu'une société de personnes a disposé de biens qui ont été assujettis à la règle sur la minimisation des pertes prévue au paragraphe 40(3.4), la fin de ce paragraphe prévoit que pour l'application de l'alinéa 40(3.4)b), la société de personnes est réputée continuer d'exister. ...

Reasons: See response CICA CRA Roundtable- September 2012 Question 9 – RRSP prohibited investments and warrants Background A registered retirement savings plan (RRSP) holds shares of a particular corporation. ...