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Reasons: See response. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 14. ... The Canada Revenue Agency's EFILE web service is now accepting transmissions of T3 returns (currently limited to only 2021 and subsequent tax years T3RET, T3S, T3M, T3RCA & T3ATH-IND return types) and T1135 Foreign Income Verification Statements. ...

Reasons: The law and continuity in our publicly shared positions since 2015. 2024 CTF Annual Tax Conference CRA Round Table Question 2 – Subsection 55(2) and Intra-Corporate Dividends Many dividend-paying public corporations rely on dividends received from their subsidiaries to fund their public dividends. ... For this purpose, the term “reasonable dividend income return on a […] listed share” refers to dividends paid regularly by widely-held corporations to their shareholders on publicly listed shares. ...

Reasons: See below 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 2. ... Put differently, the issue is not whether the transfer causes a person or partnership to receive an interest in the trust – it is that a beneficiary’s existing or future interest in the trust motivates the transferor to make the transfer. ... If Father is a contributor for purposes of determining whether he is a “resident contributor”, an analysis of the “resident beneficiary” definition is not needed. 2 Paragraph (a) provides that a contribution to a trust means a transfer or loan (other than an arm’s length transfer) of property to a trust by a particular person or partnership – in our case Father. 3 We will focus on paragraph (a) and assume paragraph (b) is otherwise satisfied. ...

STEP CRA ROUNDTABLE – June 2012 Question 11: In a recent case, Lipson v. ... Subsection 104(1) states that references in the Act to a “trust or estate (in this subdivision referred to as a trust)” include a reference “to the trustee, executor, administrator, liquidator of a succession, heir or other legal representative having ownership or control of the trust property ….” ... The Court noted that under the Code successions are dealt with in Book 3 (articles 613 – 898) whereas trusts are dealt with in Book 4 (articles 1260 to 1298) ...

Reasons: An interest in a related segregated fund trust is generally considered capital property and as such, eligible property as defined in subsection 85(1.1) for purposes of subsection 85(1). 2020 CALU CRA Roundtable – July 2020 Question 4- Segregated Fund Policies and Section 85 Rollover Background Subsection 85(1) of the Act allows for a tax-deferred transfer of “eligible property” to a corporation where the consideration includes shares of that corporation. ... Finally, paragraph 138.1(1)(e) of the Act reads in part as follows: (e) where at any particular time there is property in the segregated fund that was funded with a portion of the premiums paid before that time under a segregated fund policy, (i) the respective segregated fund policyholder is deemed to have an interest in the related segregated fund trust that is not in respect of any particular property or source of income … Based on the provisions set out above, since the disposition of a taxpayer’s deemed interest in a related segregated fund trust should result in a capital gain (as a result of not being excluded from the meaning of capital gain in paragraph 39(1)(a)), the deemed interest should also be a capital property as defined in section 54 of the Act. ... A will be the greater of 75% of the original deposit (i.e., $100,000 x 75% = $75,000) and her share of the fair market value of the investments in the segregated fund. ...

29 November 2022 CTF Roundtable Q. 7, 2022-0951051C6- Permanent Establishment and Mining Activities Unedited CRA Tags 2(3), 115(1), 253, Canada-UK Treaty art Principal Issues: In a particular situation, whether CRA will consider that UKco has a permanent establishment in Canada under Article 5 of the Canada – U.K. ... Position: Question of fact. 2022 CTF Annual Tax Conference CRA Roundtable Question 7 – Permanent Establishment and Crypto-asset Mining Equipment Crypto-asset mining can generally be described as the process of using computing power, often called “hash power”, to verify and record transactions on a blockchain. ... In the situation described above, will the CRA consider that UKco has a permanent establishment in Canada under Article 5 of the Canada – U.K. ...

Reasons: Guide T4001, Employer's Guide (Payroll Deductions and Remittances). 2021 Tax Executives Institute Annual Virtual Liaison Meeting Question 5 – Regulation 102 Pursuant to Paragraph 102(1) of the Income Tax Regulations, employers are required to withhold tax on any payment of remuneration made to an employee where the employee reports for work at an establishment of the employer. ... The CRA’s Guide T4001, Employers’ Guide – Payroll Deductions and Remittances, states: If your employee reports to your establishment in person, the employee’s province or territory of employment is the one in which your establishment is located. ... Pierre Girard / Marie-Claude Routhier 2022-092318 December 7, 2021 ...

10 June 2013 Roundtable, 2013-0480391C6- 2013 STEP CRA Roundtable Question 14 Principal Issues: CRA's intention to leverage third parties Position: General comments Reasons: See below 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 14. 2013 Federal Budget Follow Up The 2012 Federal Budget included a description of the actions being taken by federal government organizations to find efficiencies in their operations and re-engineer the way they do business. ... The discussion is in Annex 1 – Responsible Spending 2 http://www.cra-arc.gc.ca/tx/tchncl/ncmtx/ntrfls-eng.html ...

Position: Three changes will be highlighted with general comments (1) Mickey Sarazin as the new DG, (2) the new Folios project, (3) introduction of the email service Reasons: General comments provided STEP CRA Roundtable – June 2012 QUESTION 16 Can the CRA provide an update on recent administrative changes within the Income Tax Rulings Directorate that may be of interest to this audience? ... This service is not intended to replace technical interpretation letters issued on various provisions of the Income Tax Act – but rather to provide a vehicle to efficiently address general questions of interpretation or to provide responses to issues which the Directorate has previously addressed. ...

Reasons: Not a "deductible outlay or expense" in the context of 78(1) STEP CRA Roundtable – June 2012 Question 1 Would subsection 78(1) of the Income Tax Act (the “Act”) apply in respect of amounts payable by a trust to a beneficiary where the amounts so payable remained unpaid at the end of the second taxation year following the year that such amounts were deducted from the trust’s income under subsection 104(6)? ... CRA Response We are unclear as to the context in which you were seeking our comments in respect of Interpretation Bulletin IT-109R2 – Unpaid Amounts. ...