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Reasons: The repayment would not be considered to be part of a series of loans and repayments in the scenario presented. 2016 International Fiscal Association Conference CRA Roundtable Question 4 – Upstream Loans Converted to PLOIs Assume the following hypothetical facts: a) NRco, a non-resident corporation, owns all the shares of Canco, a taxable Canadian corporation. b) Canco generates $10M of excess cash and would like to provide that cash to NRco by means other than a direct distribution. c) In 2010, Canco incorporates FA, a non-resident wholly owned corporation, and transfers the $10M of cash to FA in exchange for additional shares of FA. d) FA immediately uses the cash to make a loan to NRco at an arm’s length rate of interest. e) In April 2016, NRco repays the loan to FA and FA immediately distributes the cash to Canco as a dividend out of pre-acquisition surplus. f) Canco immediately lends the cash to NRco and files a valid PLOI election under subsection 15(2.11). ...

STEP CRA Roundtable – June 10, 2016 Question 7. Deemed Resident Trust and CCPC Status A trust which meets the conditions of section 94 is considered resident for certain purposes of the Income Tax Act (the “Act”). ...

STEP CRA Roundtable – June 10, 2016 Question 15. Trust and Estate Issues Can the CRA provide an update on some of the recent issues that it has considered relating to trusts and estates? ...

CPA / CRA Red Deer, Alberta Roundtable QUESTION In Technical Interpretation 2015-0572771I7, CRA confirms that a failure to file Form T1135 on time results in the assessment of penalties under subsection 162(7), which is in Part I of the Act. ...

CALU CRA Roundtable – May 2012 Question 8- Net Cost of Pure Insurance and Paragraph 20(1)(e.2) Where a taxpayer has assigned a life insurance policy (other than an annuity contract) as collateral for a loan, and the conditions of paragraph 20(1)(e.2) of the Income Tax Act (the “Act”) are satisfied, the taxpayer is permitted to claim a deduction each year in respect of premiums payable under the policy. ...

Reasons: Textual, contextual and purposive interpretation of the Act, based primarily on subsection 247(7). 2017 International Fiscal Association Conference CRA Roundtable Question 1 – Interaction between subsections 17(1) and 247(2) Under subsection 17(1) income may, in certain circumstances, be imputed to a corporation resident in Canada in respect of an amount owing to it by a non-resident person, based on a prescribed rate. ...

Position: No Reasons: Contextual application of the definition "specified right" in subsection 18(5), as supported by the Department of Finance explanatory notes. 2017 CPA Alberta Tax Conference Question 11 – Back-to-back shareholder loans in a domestic context The Explanatory Notes to subsection 15(2.16) indicate that “it is intended that a specified right will not exist if it is established that all of the net proceeds from exercising the right…must be applied to reduce the shareholder debt”. ...

Further, the application of the various provisions in the Income Tax Act relating to foreign tax credits and deductions may yield different Canadian tax results where it is the LLC, rather than its members, that is the person paying the US tax on the LLC's income. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 16. ...

Reasons: Consistent with the law. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 13. ...

DRAFT Canadian Tax Foundation Corporate Management Tax Conference June 14, 1996 QUESTION 8 Interaction of Subsections 250(5) & 212(13.2) A U.S. corporation wishes to acquire an existing business in Canada and decides, for U.S. tax reasons, to establish a wholly-owned U.S. subsidiary ("Subco") to purchase the business. ...