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Reasons: Based on the definition of “split income” in 120.4(1). 2020 STEP CRA Roundtable – November 26, 2020 QUESTION 7. ...

Reasons: Based on technical requirements. 2020 CRA Roundtable – October 27, 2020 QUESTION 11: Refinancing Prescribed Rate Loans and the Attribution Rules An individual (other than a trust) has a prescribed rate loan at 2% for $100,000 (“Loan 1”). ...

Reasons: The general characteristics of a UK LLP more closely resemble a corporation than other forms of business association under Canadian commercial law. 2020 Canadian Tax Foundation CRA Roundtable Question 9 – Entity classification of UK LLP Under the United Kingdom’s Limited Liability Partnerships Act 2000 (as amended), a limited liability partnership governed by that statute (“UK LLP”) is treated in the United Kingdom as a separate legal entity but the profits of its business are taxed as if the business were carried on by partners in partnership, rather than by a body corporate. ...

19 May 2021 CLHIA Roundtable Q. 3, 2021-0884281C6- 2021 CLHIA Roundtable- Q3- Folios Unedited CRA Tags 148 Principal Issues: This question and answer deals with the current status of the Income Tax Folio Project and in particular, the Income Tax Folio that will replace IT-87R2, Policyholder's Income from Life Insurance Policies Position: Update provided Reasons: NA 2021 CLHIA Roundtable Question 3 – Tax Folio on Life Insurance Dispositions Background: At the CALU 2014 CRA Roundtable (Question 2) CALU noted that the Income Tax Rulings Directorate (ITRD) had started to update and improve the technical content contained in Interpretation Bulletins through the creation of a new technical tax publication called Income Tax Folios. ...

Position: No. 2021 CTF Annual Tax Conference CRA Roundtable Question 3 – Share Exchanges and section 86.1 Consider the following situation: US Pubco is a corporation incorporated under the laws of the United States (U.S.) and its common shares are listed and traded on a U.S. ...

Reasons: The CRA would consider the classification of a foreign entity in the context of an advance income tax ruling. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 16. ...

See below. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 7. Paragraph 88(1)(d.3) “as a consequence of the death of an individual” Paragraph 88(1)(d.3) of the Income Tax Act (the “Act”) states that “for the purposes of paragraphs 88(1)(c), (d) and (d.2), where at any time control of a corporation is last acquired by an acquirer because of an acquisition of shares of the capital stock of the corporation as a consequence of the death of an individual, the acquirer is deemed to have last acquired control of the corporation immediately after the death from a person who dealt at arm's length with the acquirer”. ...

Reasons: The law allows a graduated rate estate to have a taxation year-end other than a calendar year, including in the year of wind-up. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 10. ...

CLHIA CRA Roundtable September 28, 2023 Question 5 – Section 147.4 Copycat Annuity Background A member of a flexible pension plan may be entitled to a commuted value from the plan and the plan may permit members to acquire additional benefits with their optional ancillary contributions (“OACs”) and/or to purchase an annuity with the commuted value. ...

Position: See details in response. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 15. ...