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Reasons: Wording of the Act 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 14. ...

Accordingly, there is no relevant day of death for purposes of the preamble of subsection 104(13.4). 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 13. ...

If not, there may not be a "related business" 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 4. ...

In this regard, we note that the partnership look through rule in subsection 17(4) was enacted (in 1999) concurrent with the introduction of subsection 17(8) and the amendment to subsection 247(7) to refer to subsection 17(8). 2021 International Fiscal Association Conference CRA Roundtable Question 5 – Applicability of subsection 247(7) Consider a situation where two corporations (ACo and BCo), each of which is resident in Canada, are related within the meaning of subsection 251(2). ...

As such, the conditions for the application of subsection 261(21) are not satisfied. 2021 CTF Annual Tax Conference CRA Roundtable Question 11 – 261(21), Loan to FA and Excluded Property In response to question 4 of the 2017 IFA tax conference, the CRA commented on the application of subsections 261(20) and (21) (published in CRA document 2017-0691211C6). ...

Reasons: Scheme of the Act. 2022 CALU CRA Roundtable – May 2022 Question 5- Policy Loan and Deduction under Paragraph 60(s) Background For the purposes of section 148 of the Income Tax Act (the “Act”), taking a policy loan under a life insurance policy is a disposition of an interest of a life insurance policy. ...

CALU Roundtable- May 2022 Question 7 – Life insurance shares Background The CRA has previously considered life insurance shares in the context of determining how the cash surrender value (CSV) of a corporate-owned life insurance policy is allocated between various classes of shares including life insurance shares, for the purposes of subsection 70(5.3) of the Income Tax Act (the “Act”) on the death of a shareholder. ...

Reasons: On the facts of this Question 14 and on the assumption that the partnership is the relevant taxpayer in subsection 90(3), there is no connected person or partnership in respect of the taxpayer as defined in subsection 90(4). 2022 International Fiscal Association Conference CRA Roundtable Question 14 – Partnership and Subsection 90(3) Election A distribution made by a foreign affiliate of a taxpayer in respect of a share of its capital stock will be a qualifying return of capital pursuant to subsection 90(3) of the Act where the following conditions are met: (i) the distribution is a reduction of the paid-up capital of the foreign affiliate in respect of the share, (ii) the distribution would otherwise be deemed under subsection 90(2) to be a dividend paid or received on the share, and (iii) an election is made in respect of the distribution in accordance with prescribed rules. ...

The election can only be made by an alter ego trust, the terms of which are described in clause 104(4)(a)(iv)(A). 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 2. ...

Reasons: Based on the CRA’s long-standing position on debt settlement in various factual situations relevant to this issue. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 5. ...