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These are additions to our set of 2,290 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 18 ¾ years of releases of such items by the Directorate. ...

Income Tax Act- Section 246- Subsection 246(1)- Paragraph 246(1)(a) s. 246(1)(a) application re mother’s use of a car of Opco controlled by her son’s Holdco to her rather than son turned on whether her minority Holdco had significant influence over Opco Income Tax Act- Section 15- Subsection 15(5) application of s. 15(5) to shareholder’s use of company automobile Income Tax Act- Section 10- Subsection 10(1) automobiles in car dealer inventory used for employee’s personal use remained in inventory, cf. if converted primarily to personal use of shareholder (which would not be a disposition) Income Tax Act- Section 9- Computation of Profit conversion of automobile in car inventory to personal use of CEO would not entail its deemed disposition nor would the conversion of car inventory to personal use of shareholders 2003-11-07 30 October 2003 External T.I. 2003-0037465 F- Subsections 40(3.3) & 40(3.4) Also released under document number 2003-00374650. ...

These are additions to our set of 2,363 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ¼ years of releases of such items by the Directorate. ...

Income Tax Act- Section 153- Subsection 153(1)- Paragraph 153(1)(a) payment of deferred commission amounts held as contingency loss reserve from old employer to new employer was a payment of “remuneration” subject to withholding General Concepts- Payment & Receipt constructive receipt by employee where reserve loss account (funded out of commissions) is transferred from old brokerage employer to new brokerage employer 2003-10-03 24 September 2003 External T.I. 2003-0028145 F- DON FAIT PAR UN PARTICULIER NON-RESIDENT Also released under document number 2003-00281450. ...

These are additions to our set of 2,417 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,445 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ¾ years of releases of such items by the Directorate. ...

These are additions to our set of 2,458 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 19 ¾ years of releases of such items by the Directorate. ...

Income Tax Act- Section 5- Subsection 5(1) salary that is forfeited by RCMP officer for misconduct nonetheless is includible as salary which was constructively received General Concepts- Payment & Receipt forfeited salary nonetheless includible as salary received ...

Topic Descriptor 17 May 2023 IFA Roundtable Q. 1, 2023-0964391C6- stock based compensation and transfer pricing Income Tax Act- Section 7- Subsection 7(3)- Paragraph 7(3)(b) s. 7(3)(b) non-deduction or s. 112(1)(e) deductibility could apply to cross-border stock option recharges of non-resident parent Income Tax Act- Section 247- New- Subsection 247(2) stock-compensation expenses may be relevant to pricing cross-border services charges even where s. 7(3)(b) prohibits their deduction 17 May 2023 IFA Roundtable Q. 2, 2023-0964301C6- Ukraine Russia FAs and Tax Reporting Income Tax Act- Section 233.5 failure to file complete information for affiliate in war-torn country Income Tax Act- Section 220- Subsection 220(2.1) potential relief from return-filing requirements re FA in war-torn country 17 May 2023 IFA Roundtable Q. 3, 2023-0964551C6- T1134 Supplement Income Tax Act- Section 233.5 T1134 should be timely-filed with missing information noted Income Tax Act- Section 90- Subsection 90(2) a pro rata distribution by an LLLP to its members is a dividend 17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit” Treaties- Income Tax Conventions- Article 29 Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion 17 May 2023 IFA Roundtable Q. 5, 2023-0965771C6- Remote Work Arrangements Income Tax Act- Section 253- Paragraph 253(b) s. 253(b) does not extend to “invitation to treat” or advertisement Income Tax Act- Section 253- Paragraph 253(a) product development from Canadian home office might engage s. 253(a) Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) whether Canadian home offices of US employees can give rise to it carrying on business in Canada Treaties- Income Tax Conventions- Article 5 whether employee’s home office can constitute a PE of US employer 17 May 2023 IFA Roundtable Q. 6, 2023-0964351C6- Application of the Canada-US Treaty Treaties- Income Tax Conventions- Article 4 Treaty benefits could be created for a s. 216 structure by creating partnerships for US purposes 15 September 2020 IFA Roundtable Q. 7, 2020-0853571C6- Regulation 5901(2)(b) Pre-Acquisition Surplus Election Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b)- Subparagraph 5901(2)(b)(ii) Reg. 5901(2)(b)(ii)(A) does not taint a siloed dividend paid by FA to Canco1 even though another Canco holds other FA shares through an LP 17 May 2023 IFA Roundtable Q. 7, 2023-0964521C6- Application of Article 10, Canada-Hong Kong Treaties- Multilateral Instrument- Article 7- Article 7(1) the PPT object and purpose test is met where individuals in a Treaty country transfer their Canco shares to a Treaty-resident Holdco to reduce dividend withholding Treaties- Income Tax Conventions- Article 10 violating main purpose test in HK Treaty increases dividend rate/ PPT object and purpose test not violated by using personal holding company in same jurisdiction 17 May 2023 IFA Roundtable Q. 8, 2023-0964561C6- Tax-free Surplus Balance and Paragraph 88(1)(d) Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(d)- Subparagraph 88(1)(d)(ii)- Variable C surplus computation not required in typical bump and run transaction Income Tax Regulations- Regulation 5905- Subsection 5905(5.4) no surplus calculations needed where FA of Canadian target is acquired by Forco through a Cdn. ...

These are additions to our set of 2,577 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ¾ years of releases of such items by the Directorate. ...