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Reasons: See response. 2021 CTF Annual Tax Conference CRA Roundtable Question 7 – Sub-funds and the Tracking Interest Rules in Subsections 95(8) to (12) Assume that a taxpayer owns shares of a non-resident umbrella corporation contemplated by the tracking interest rules in subsections 95(8) to (12). ...

Reasons: See below. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 3. ...

Reasons: See below. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 11. ...

Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 6. ...

Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 8. ...

STEP CRA Roundtable – June 13 2017 Question 4. US Grantor Trust A Canadian resident individual (Mr. ...

Reasons: See comments. 2018 CTF Annual Conference CRA Roundtable Question 9: TOSI – Excluded Amount and the Non-Related Business Exception Under the definition of “excluded amount” in subparagraph 120.4(1)(e)(i), an amount will not be split income of a specified individual who has attained the age of 17 years before a taxation year in circumstances where it is not derived directly or indirectly from a “related business” in respect of the individual for the year. ...

Reasons: Wording of the provision. 2019 STEP CRA Roundtable – June 7, 2019 QUESTION 5. ...

Position: General comments provided. 2024 CTF Annual Conference CRA Roundtable Question 12 – Property flipping rules and corporate property transfers The flipped property rules contained in subsections 12(12) to 12(14) of the Act (the “Flipped Property Rules”) provide a deeming rule (in subsection 12(12) of the Act) that results in a gain on the disposition of a housing unit that is flipped property being fully taxable as business income. ...

Position: Based on the policy objectives set out in the explanatory notes for the transition rules and the amendments to section 87 and 88 and the coming into force of the amendments it is reasonable to extend the application of paragraph 87(2.1)(a.1) and subsection 88(1.11) to the transitional amounts applicable in the pre-regime period notwithstanding these provisions do not explicitly refer to the terms used in the pre-regime transition rules. 2024 CTF Annual Tax Conference CRA Roundtable Question 6 – EIFEL- Pre-Regime Election and Amalgamations and Liquidations The legislation enacting sections 18.2 and 18.21 of the Act (which are the main provisions of the Excessive Interest and Financing Expenses Limitation Regime or EIFEL rules) includes a pre-regime election (footnote 1) in the coming into force provision that allows a taxpayer to elect to calculate its excess capacity for each of the three taxation years (the pre-regime years) immediately preceding its first taxation year (the first regime year) in respect of which the EIFEL rules apply. ...