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Technical Interpretation - External summary
4 March 2014 External T.I. 2013-0491981E5 F - Soins à un conjoint inapte -- summary under Business Source/Reasonable Expectation of Profit
. … In Johanne Maurice v. The Queen, 2001 DTC 3710, Mrs. Maurice was receiving amounts in her capacity as a tutor for home help services she personally provided to her mentally incompetent daughter, a minor. ...
Technical Interpretation - External summary
19 August 2015 External T.I. 2015-0589611E5 - loss consolidation arrangements -- summary under Paragraph 111(1)(a)
CRA responded: S3-F6-C1 … paragraph… 1.71… indicates that such loss consolidation arrangements could be undertaken by parties that are related but not affiliated (as well as parties that are both related and affiliated and parties that are affiliated but not related). ...
Technical Interpretation - Internal summary
10 August 2015 Internal T.I. 2014-0527981I7 - Application of 146.1(2.21) to deceased beneficiary -- summary under Subsection 146.1(2.21)
. … [T]he phrase “to or for an individual” in subsection 146.1(2.21) must apply in respect of a living individual and an EAP cannot be paid in respect of a beneficiary once the beneficiary in question is deceased. ...
Conference summary
9 October 2015 APFF Financial Strategies and Instruments Roundtable Q. 9, 2015-0596611C6 F - Transfer 70(6) -- summary under Subsection 70(6)
translated at Q.9 S. 70(6) rollover for replacement property
. … If an executor, in performing the estate administration, is under an obligation to dispose of property or he exercises his power to dispose of the property… subsection 70(6) is not complied with since the property has not vested indefeasibly in the trust. ...
Conference summary
9 October 2015 APFF Roundtable Q. 6, 2015-0595551C6 F - Capital Dividend Account -- summary under Paragraph 87(2)(z.1)
translated at Q. 6 Negative amalgamation effect on combined CDA
(b) of the CDA definition from the receipt of the dividend – so that Holdco can then pay a capital dividend of $1M to its individual shareholder. ...
Conference summary
9 October 2015 APFF Roundtable Q. 6, 2015-0595551C6 F - Capital Dividend Account -- summary under Capital Dividend Account
translated at Q. 6 Negative amalgamation effect on combined CDA
(b) of the CDA definition from the receipt of the dividend – so that Holdco can then pay a capital dividend of $1M to its individual shareholder. ...
Conference summary
24 November 2015 CTF Roundtable Q. 1, 2015-0610691C6 - T2 Late-Filing: Impact on Div. Refund and RDTOH -- summary under Subsection 129(1)
. … As well, the CRA will consider that a dividend recipient’s Part IV tax liability with respect to a dividend received from a connected dividend payer will be determined according to the dividend refund actually received by the dividend payer. ...
Technical Interpretation - Internal summary
5 November 2015 Internal T.I. 2015-0585381I7 - Paragraph 95(2)(k) - Fresh Start Rules -- summary under Paragraph 95(2)(k)
Standard Life took essentially the opposite approach to the interpretation of a similar requirement under s. 138(11.3) – so that it was necessary for the taxpayer to qualify as an "insurer" in the preceding taxation year rather than only in the current year, in order for an asset bump to be available. ...
Technical Interpretation - Internal summary
1 March 2016 Internal T.I. 2016-0631181I7 - Specified foreign property - mineral rights -- summary under Specified Foreign Property
(b) of 233.3(1) – “specified foreign property,” CRA stated: We wish to clarify that a specified foreign property can include inter alia tangible or intangible property…., real property can include… intangible property…[and] a mineral right would likely be considered an intangible property. ...
Technical Interpretation - External summary
29 February 2016 External T.I. 2015-0613961E5 - Patronage dividends - partnership income -- summary under Income of the Taxpayer Attributable to Business Done With Members
. … [A] taxpayer’s share of partnership income from a Canadian limited partnership is required to be included in computing its income for the year for purposes of [that] definition…. ...