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C’s income pursuant to s.104(13) would be considered to be US-source income – and we assume this throughout the rest of the answer. ... In many cases, however, the terms of the trust that is affected by subsection 75(2) will not have any amounts paid or payable to the contributor / settlor and ultimately the taxation of the applicable amounts in the contributor / settlor’s hands is only because of subsection 75(2) and not subsection 104(6). Accordingly, when preparing the accounting records for the trust, the subsection 75(2) attributed amounts are not recorded as being paid or payable to the contributor / settlor since the facts of the particular case will often not require the actual payment of such amounts to the contributor / settlor. ...

Of particular relevance to this specific question is the definition of “advantage” in 207.01(1) – advantage- (b)(i). ... They are the main sources of referrals to the Committee – although the Committee also considers advance income tax ruling requests on the GAAR. ... LLC that is a foreign affiliate and has a single member which is a regarded U.S. corporation should compute its “earnings” in accordance with Reg. 5907(1) – earnings- s. ...

The length of time would have to be appropriate, so there is no set period of time – it depends on the circumstances as to which period should be considered to make the determination. ... There is a common theme with the two prior responses – crypto is subject to the same obligations of keeping proper supporting documentation, in respect of crypto asset transactions. ... The discretionary relief has to be requested in prescribed form – RC4288. ...

To make a request to cancel penalties or interest, businesses or their authorized representatives should fill out Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties or Interest. ... Q.21- Court Cases / Objections Please provide an update on recent and current court cases and objections. ...

Meaning of "trust & loan corporation" CRA Comments Q.20. ... Meaning of "trust & loan corporation" Summary of Question A person whose principal activity is purchasing debt securities is a listed financial institution. ... QST administration by the Canada Revenue Agency: Quebec SLFI’S Summary of Question Pension entities with more than 90 % of their members in Quebec and less than 10% of their members in another province became Quebec SLFIs under the new Quebec Sales Tax ("QST") regime as of January 1st 2013. ...

See Taitz & Millar, ‘‘The GST and National Religious Organizations – Selected Issues”, GST & Commodity Tax (Carswell), Vol. ... The schedule to that Notice of Ways and Means Motion to Amend the Excise Tax Act contained the following text with respect to section 155: “ Section 155 — Non-Arm's Length Supplies by Public Sector Bodies: Section 155 provides an anti-avoidance rule that deems certain non-arm's length supplies made for less than fair market value to be made for fair market value. ... A determination of the LP’s primary purpose would generally reflect its main or fundamental purpose at the time it was established – and may be reassessed later on. ...

The CRA requires that form T2075 be filed twice – this is noted at the top of the form. ... A forgiven amount at any time is determined by the formula A – B, under that definition in s. 80(1). ... Official Response 15 June 2022 Roundtable, 2022-0924791C6- STEP 2022 – Q18- McNeeley et al v. ...

".] We do not have enough information to know how Mr. A participates in the management of the business of Aco and SENC. ... C.C.Q. 12 CANADA REVENUE AGENCY, " CRA Update on Subsection 55(2) and Safe Income- Where Are We Now? ", April 10, 2024 13 Subject to the positions taken by the CRA on the possibility of invoking the general anti-avoidance rule in certain circumstances. ...

Potential abuse of integration principle However, the D & D Livestock case illustrates how s. 55(2) can be instrumental in not only preventing the duplication of taxes, but might also be instrumental in generating ACB that is unsupported by taxed corporate income. ... D & D Livestock addressed We will not go over the facts of D & D Livestock in detail. ... Some people have been wondering about the fact that in D & D, there was a sale that was contemplated and whether the changes to proposed s. 55(2) would be limited to circumstances where a potential buyer has been identified or where there is a potential sale as part of a series in the traditional sense or in the extended sense under s. 248(10). ...

(a) In the first situation, since the down payment was fully paid by A, A will be considered to have made a gift of $50,000 to B at the time of purchase (50% × $100,000). ... Instead, could the ACB of each be allocated as follows: A: $250,000 ($100,000 + (50 % × $300,000)) B: $150,000 (50 % × $300,000) b) In the second situation, in CRA's opinion, pursuant to Art. 1015 C.C.Q. of the Civil Code, will each be required to report the following proceeds of disposition and ACB in 2021 A (50 %): $350,000- $200,000 B (50 %): $350,000- $200,000 Is it then reasonable to conclude that the $100,000 priority payment to A actually includes the repayment by B of a loan made to B by A at the time of purchase, being 50% of the $100,000 down payment, or $50,000? ... The CRA is of the view that the word "consideration" in the phrase "fair market value of any consideration … received by the donee for the disposition … of the security" in paragraph 118.1(13)(c) must be given the broad meaning generally accepted in the jurisprudence. ...