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Tax Treaty are met. 2024 STEP CRA Roundtable – June 4, 2024 Question 11. ...

Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 7. ...

However, subsection 248(28) will apply to prevent the amount of the Overpayment from being included twice in computing the income of the Shareholder Employee such that subsection 15(1) would not apply to tax the amount of the Overpayment as a Shareholder Benefit; 2B) The rule provided in paragraph 15(1.4)c) will not apply to include the amount or value of that benefit in computing the Shareholder's income pursuant to subsection 15(1) because the amount of the Overpayment is included in computing the income from employment of the Shareholder Employee. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 2. ...

(B) As the trust will continue to be a post-1971 spousal or common-law partner trust, the carve out in subparagraph (g)(i) of the definition “trust” in subsection 108(1) applies. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 1. ...

Therefore, if a particular trust holds a GIC issued by a Canadian bank or trust company, it would not be a trust described in paragraph 150(1.2)(b). 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 9. ...

Reasons: The CRA would consider the classification of a foreign entity in the context of an advance income tax ruling. 2024 IFA Annual Conference CRA Roundtable Question 2 – Foreign Entity Classification The common limited partnership (société en commandite simple (SCS)) and the special limited partnership (société en commandite spéciale (SCSp)) are common types of entities used for investment funds in Luxembourg. ...

STEP CRA Roundtable – June 18 2015 Question 7- Deemed Resident Trust Question 7(a) Under the rules concerning deemed resident trusts, an individual who becomes resident in Canada for the first time, and who has previously contributed property to a non-resident trust, will be considered a resident contributor. ... A resident contributor is defined in subsection 94(1) as "a person that is, at that time, resident in Canada and a contributor to the trust …" Contributor is defined in subsection 94(1) as "a person (other than an exempt person but including a person that has ceased to exist) that, at or before that time, has made a contribution to the trust. ...

Ontario CTF Conference – October 30, 2012 Question 13 Part 1 Assume that Mr. ...

Reasons: Based on previous ITRD positions. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 9. ...

Reasons: See below. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 17. ...