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., ensuring compliance with ITA requirements including monitoring for non-qualified investments and ensuring all transactions occurred at fair market value), and stated: In light of these statutory duties and obligations, the central management and control of a TFSA trust will rest with, and be exercised by, the trustee in Canada … [so that] a TFSA trust will always be considered resident in Canada for the purposes of the Act. ...

However, as CRA does not take into account interest relating to acquisitions by a partnership of FA shares for 93.1(2)(d)(i) limit purposes, the s. 113(1) deduction of Canco is $1,000 rather than $700 – so that in computing its taxable income, Canco would have a loss of $300 (i.e., partnership income of $700, minus a s. 113(1)(a) deduction of $1,000). ...

[Reg.] 209(4) … defines express consent to be consent given in writing or in an electronic format. ...

Therefore … in the example above, the CRA would not assess interest. ...

2017 Ruling 2017-0699201R3- Cross-border Butterfly-- summary under Subsection 143.3(3) Summary Under Tax Topics- Income Tax Act- Section 143.3- Subsection 143.3(3) s. 143.3(3) inapplicable on a 4-party exchange CRA ruled on a cross-border butterfly which entailed assets of the “Transferred Business” being transferred indirectly to a wholly-owned non-resident subsidiary (Foreign Spinco) of a non-resident public company (Foreign Parentco) or to a wholly-owned non-resident subsidiary of Foreign Spinco (Foreign Spinco Sub) – with a view to the shares of Foreign Spinco being dividended out to the shareholders of Foreign Parentco at the transactions’ completion. ...

2017 Ruling 2017-0699201R3- Cross-border Butterfly-- summary under Adjusted Cost Base Summary Under Tax Topics- Income Tax Act- Section 54- Adjusted Cost Base full cost of property acquired under 4-party exchange CRA ruled on a cross-border butterfly which entailed assets of the “Transferred Business” being transferred indirectly to a wholly-owned non-resident subsidiary (Foreign Spinco) of a non-resident public company (Foreign Parentco) or to a wholly-owned non-resident subsidiary of Foreign Spinco (Foreign Spinco Sub) – with a view to the shares of Foreign Spinco being dividended out to the shareholders of Foreign Parentco at the transactions’ completion. ...

After referring to the desirability of “timesheets, schedules, or logbooks” or payroll records showing hours, CRA recognized “the challenges presented” for demonstrating the 20-hour test for pre-2018 years, and stated: Where … information is provided in support of assertions that the 20 hour per week threshold was met in prior years, the CRA will if necessary, consider whether the assertions are reasonable having regard to such factors as The type of business and duties performed as they relate to the main activities of the business The individual’s education, training and experience Any particular knowledge, skills or know-how that the individual possessed Going forward, the ongoing maintenance of such records in respect of any family members involved in the business will ensure that businesses are able to comply with the new rules and obtain the benefits of available exclusions, even as family members leave the business. ...

CRA responded: …CRA has applied … IT-143R3 [para. 23]: “Since an outlay or expense is an eligible capital expenditure only if it is incurred for the purpose of gaining or producing income from a business, legal and accounting fees incurred in an abortive attempt to acquire shares of a corporation would normally not qualify. ...

After first assuming that there was no event causing a deemed year end, CRA indicated that under s. 249(1)(b) and 249(5), the taxation year for a graduated rate estate is based on the period for which the accounts are normally made up, which would end with the final distribution date – so that the return due date is 90 days after the final distribution. ...

X would not be a connected contributor to Trust A or Trust B, and … there would not be a resident beneficiary under Trust A or Trust B. ...