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Response: New issues with paragraphs IV(6) & IV(7) Since the 2007 signing of the Fifth Protocol to the Canada-United States Tax Convention (the "Treaty"), the Canada Revenue Agency (the "CRA") has been asked to consider many strategies designed to ensure that either paragraph (6) of Article IV does apply to a particular amount, or that paragraph (7) of that Article does not apply to a particular amount, along with the possible application of the general anti-avoidance rule. ...

Position: General comments, no position taken; Florida LLLPs and LLPs are presently being considered and interested parties are invited to provide comments. 2015 International Fiscal Association Conference CRA Roundtable Question 3 – Entity Classification It is our understanding that the CRA generally follows a so-called "two-step" approach in classifying foreign entities or arrangements, as follows: 1. ...

CTF Prairie Tax Conference 2012 Round Table Question 18 Proposed Subsection 89(14.1) – Late Eligible Dividend Designations This question is related to the payment of eligible dividends. ...

Reasons: See document STEP CRA Roundtable – June 2012 Q15 In U.S. estate planning, revocable trusts are well accepted and commonly used. ...

Reasons: A deemed gain or loss on capital account under ss. 261(10) is considered to be a capital gain or loss for the purposes of ss. 39(2) and such gain or loss is eligible for ss. 39(2.1) relief where its other conditions are met. 2015 International Fiscal Association Conference CRA Roundtable Question 8 – Subsection 39(2.1) and Functional Currency Tax Reporting Subsection 39(2.1) of the Act applies to reduce a capital gain or capital loss, as determined under subsection 39(2), where a corporation resident in Canada (the "borrowing party"), has received a loan from its foreign affiliate prior to August 20, 2011, a partial or full repayment of the loan is made prior to August 20, 2016, and the borrowing party's capital gain or loss matches the affiliate's capital loss or gain, as the case may be. ...

STEP CRA Roundtable- June 2014 Question 19 – Multiple Assessments Suppose that a taxpayer carried out a series of transactions, where the tax consequences of each transaction are relevant to the next transaction. ...

Reasons: According to the jurisprudence. 2015 CTF Annual Conference CRA Roundtable Question 4: GAAR Committee Decision – Planning Involving the Intentional Use of Subsection 55(2) to Generate Capital Gains Consider the following scenario: Mr. ...

CALU CRA Roundtable- May 2012 Question 7 – Co-Ownership of a Life Insurance Policy Background At the 2010 CALU Roundtable, the CRA was asked about the tax consequences of an arrangement between a parent and subsidiary corporation where one was the policyholder and the other was the beneficiary of the policy. ...

Reasons: See document. 2016 CTF Annual Conference CRA Roundtable Question 8: 55(2) Fundamental Principles – Is cash a “property” for purposes of clause 55(2.1)(b)(ii)(B) Is cash considered to be property for purposes of the application of clause 55(2.1)(b)(ii)(B)? ...

Reasons: Granting the administrative relief requested would not be consistent with the purpose of the T1134 reporting requirement. 2017 International Fiscal Association Conference CRA Roundtable Question 6 – T1134 filing issues The CRA has provided some administrative relief from duplicate or repetitive reporting for form T1134. ...