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December 6, 2011 Question 14- Section 79.1 Seizure of Property — Effect on Creditor Section 79.1 applies when a property is seized at any time by a person in respect of a debt. ... Paragraph 4 of IT-437R states: ¶ 4. Beneficial ownership must be distinguished, however, from the other types of physical possession of property which a person may enjoy. ...

The words " a property" refers to a singular property such that the election can be used in respect of only one property of all the property distributed. 2. See document STEP CRA Roundtable – June 2014 QUESTION 18. Electing to have Subsection 107(2.1) Apply Subsection 107(2) provides the rules for the "rollout" of the property of a personal trust to a beneficiary under the trust in full or partial satisfaction of the beneficiary's capital interest in the trust. ...

For example, in Canadian & Foreign Securities Co. v. M.N.R., [1972] C.T.C. 391 at 395 (F.C.T.D.), the Court stated (at 395): I think it undesirable to attempt, in this judgment, any all-encompassing statement as to the meaning of "securities" in this section of the Income Tax Act [R.S.C. 1952, c.148, s. 69(2)(c)], I am, however, satisfied that Parliament used the word in a popular sense, so as to include instruments for the payment of money with or without some collateral obligation and which are commonly dealt in for the purpose of financing and investment. ... Paragraph 53(1)(e) includes in paid-up capital, " all indebtedness, represented by bonds, bond mortgages, debentures, income bonds, income debentures, mortgages, lien notes, and any other securities to which the property of the corporation of any of it is subject". ...

The conditions for the joint election are provided in paragraph 104(13.4)(b.1). 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 11. ... Paragraph 104(6)(b) calculates the maximum deductible amount available to the trust as A – B. ...

Accordingly, arrears interest should not apply. 2020 STEP CRA Roundtable – November 26, 2020 QUESTION 2. ... This is claimed by filing form T3A – Request for Loss Carryback by a Trust. ...

Reasons: A strict textual reading of subsection 40(3.61) could otherwise produce an iterative "grind", which is contrary to the intended relief of the provision. 2020 STEP CRA Roundtable – November 26, 2020 QUESTION 5. ... Subsection 40(3.6) would apply to any capital loss of the estate that remains after the election is made – in this case, the remaining capital loss of $30,000 would be deemed to be nil. ...

STEP CRA Roundtable – June 2014 QUESTION 5. "Evil Trusts" The term "evil trust" has become used within the tax community to denote a trust which is structured to deliberately cause the application of subsection 75(2). ...

Reasons: See below. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 11. ...

STEP CRA ROUNDTABLE – June 2012 QUESTION 6 It is common in dealing with an owner-manager business to see a shareholder draw money from the corporation during the year, and repay the amount at the corporation's year end, or within one taxation year, often by the offset of an amount credited to the shareholder from payment of a dividend or a bonus (net of withholding tax). ...

STEP CRA Roundtable- June 18, 2015 Q 12- New Charitable Donation Rules – Part 2 Under the new tax legislation dealing with testamentary gifts, the "taxpayer" making the gift will be the deceased's estate (paragraph 118.1(5)(a) provides that the gift is deemed to be made by the estate and not by any other taxpayer).  ...