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Reasons: The law does not allow for a trust, other than a graduated rate estate, to have a taxation year end other than a calendar year in the year of wind up. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 3. ...

Reasons: Public information available on the CRA website. 2018 STEP CRA Roundtable – May 29, 2018 Question 18. ...

Reasons: In accordance with the provisions of the Act and our previous positions. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 10. ...

THE INSTITUTE OF CHARTERED ACCOUNTANTS OF NOVA SCOTIA ROUND TABLE FEBRUARY 1994 Question # 7 ANNUITIES PURCHASED FROM CHARITABLE ORGANIZATIONS The Department's position as outlined in Interpretation Bulletin IT-111R allows a charity to pay an amount as an annuity back to a donor who has made a contribution to the charity. ...

Position: Question of fact Reasons: n/a TEI QUESTION- JUNE 1996 CONFERENCE NON-RESIDENT WITHHOLDING TAXES- SECTION 212 & REGULATION 105 Does the Minister consider that withholding under either paragraph 212(1)(d) or Regulation 105 of the Act apply in the following circumstances? ...

27 November 2018 CTF Roundtable Q. 3, 2018-0779891C6- MLI Issues Principal Issues: General comments on the MLI Position: See below 2018 Canadian Tax Foundation Annual Conference CRA Roundtable Question 3 – Multilateral Instrument Issues Canada introduced legislation to implement the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”): https://www.fin.gc.ca/n18/18-037-eng.asp. ...

Reasons: see below. 2018 CTF Annual Conference CRA Roundtable Question 1: Allocation of safe income to discretionary dividend shares – study update At the 2016 CTF Annual Conference, the CRA indicated that it was conducting a study of how safe income should be allocated for corporations that have issued shares that are entitled to discretionary dividends, and when a dividend disproportionate to the respective pro rata interest is declared on such shares. ...

Reasons: In the scenario provided the Will directs the executor to pay the residue of the estate to the beneficiary. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 11. ...

These unique identifiers allow the CRA's T3 Assessing section to track the GRE to the deceased individual. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 10. ...

Reasons: Due to delay in the discussions between the RPD and other government regulators relative to their pension benefits standards legislation. 2020 CALU CRA Roundtable – July 2020 Question 9- CRA Newsletter on section 147.4 annuities Background In December 2018, the Registered Plans Directorate (RPD) issued a draft newsletter for industry consultation relating to registered annuities issued under section 147.4, Conference for Advanced Life Underwriting (CALU) welcomed the efforts of the RPD to provide more clarity on what conditions need to be satisfied in order for a third-party annuity, which is acquired in satisfaction of a member's rights to benefits under a registered pension plan, to qualify under section 147.4. ...