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Many of the comments made by the Department in IT-73R4 have recently been upheld by the Federal Court Trial Division decision in Hughes & Co. ...

Reasons: Update provided by the Appeals Branch. 2018 CTF Annual Conference CRA Roundtable Question 6 – Appeal Process Update CRA published several commitments to improve the appeal process as part of the December 2016 Auditor General Report. ...

Whether the amount of the benefit can be considered to be taxable income earned in Canada will depend, among other things, on the nature of the benefit being conferred. 2019 International Fiscal Association Conference CRA Roundtable Question 7 – Subsection 246(1) and Non-Residents Would the CRA apply paragraph 246(1)(a) of the Income Tax Act (the “Act”) to include in a non-resident’s taxable income earned in Canada an amount of an indirect benefit from a non-resident, where the benefit is not from one of the three Canadian income sources described in subsection 2(3) of the Act, being employment in Canada, carrying on business in Canada and dispositions of taxable Canadian property? ...

Reasons: Consistent with CRA’s previous positions provided in document 9521415. 2019 International Fiscal Association Conference CRA Roundtable Question 1 – Thin Capitalization and Specified Shareholder The thin capitalization rules set out in subsection 18(4) of the Income Tax Act (the “Act”) limit the deductibility of interest paid or payable on outstanding debts to specified non-residents, such that, in general terms, a corporation may not deduct interest based on the proportion of such debts over and above 1.5 times the “equity amount” of the corporation. ...

Reasons: The dividend income paid to USco is not derived from Canada in connection with or incidental to the trade or business of USco. 2019 International Fiscal Association Conference CRA Roundtable Question 8 – Active Trade or Business Test under the LOB Clause Paragraph 3 of Article XXIX-A (this Article hereinafter referred to as the “LOB Clause”) of the Canada-U.S. ...

CLHIA Roundtable – May 2019 Question 6- Application of Exempt Test to Life Insurance Policies issued on Non-Resident Lives Background The preamble to Income Tax Regulation 306(1) indicates that a life insurance policy that is exempt from accrual taxation must, first and foremost, be a life insurance policy (other than an annuity contract, LIA policy, or a deposit fund administration policy). ...

Reasons: A referral to examine the other accounts is sent in specific situations and solely to ensure compliance from the employer. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 15. ...

Reasons: Previous positions. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 8. ...

Reasons: See below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 13. ...

Reasons: See below. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 1. ...