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Reasons: See below. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 12. ...

Reasons: See response below. 2022 STEP CRA Roundtable – June 15, 2021 QUESTION 4. ...

As any tax-free surplus grind to the bump would result in a gain on disposition which would be eliminated with a 93(1) election, the requirement for tax-free surplus calculations would be a redundant exercise since surplus available for a 93(1) election would generally equal the tax-free surplus balance. 2023 IFA Annual Conference CRA Roundtable Question 8 – Tax-free Surplus Balance Calculation and Paragraph 88(1)(d) “Bump” At the 2011 IFA Conference CRA Roundtable (CRA document 2011-0404521C6), the CRA indicated that it would not challenge a paragraph 88(1)(d) bump in respect of the shares of a foreign affiliate (FA) by raising an issue with an FA’s tax-free surplus balance (TFSB) calculation or lack thereof in circumstances where, absent clause 88(1)(d)(ii)(C), the shares of FA could be bumped to fair market value such that there would be no gain on a subsequent distribution of the FA shares to a foreign parent, provided that no dividends were paid or were deemed to be paid on the FA shares following the acquisition of control and the FA shares were distributed to the foreign parent within a reasonable amount of time. ...

Although the CRA may provide relief in respect of the provision of prescribed information normally required in foreign reporting forms, the forms must still be filed by the taxpayer on or before the respective form’s filing due date. 2023 International Fiscal Association Conference CRA Roundtable Question 2 – Ukraine/Russia Reporting Requirements Some Canadian multinationals have subsidiaries in Ukraine or Russia that continued operating during 2022 in those countries. ...

CALU Roundtable- May 2024 Question 7 – Prescribed Annuity Contracts and Trusts A prescribed annuity contract (PAC) is a type of immediate annuity contract (i.e. payments have commenced) that is not subject to annual accrual tax reporting under subsection 12.2(1) of the Income Tax Act (the “Act”) by virtue of the exception set out in paragraph 12.2(1)(b) of the Act. ...

Tax Treaty are met. 2024 STEP CRA Roundtable – June 4, 2024 Question 11. ...

Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 7. ...

However, subsection 248(28) will apply to prevent the amount of the Overpayment from being included twice in computing the income of the Shareholder Employee such that subsection 15(1) would not apply to tax the amount of the Overpayment as a Shareholder Benefit; 2B) The rule provided in paragraph 15(1.4)c) will not apply to include the amount or value of that benefit in computing the Shareholder's income pursuant to subsection 15(1) because the amount of the Overpayment is included in computing the income from employment of the Shareholder Employee. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 2. ...

(B) As the trust will continue to be a post-1971 spousal or common-law partner trust, the carve out in subparagraph (g)(i) of the definition “trust” in subsection 108(1) applies. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 1. ...

Therefore, if a particular trust holds a GIC issued by a Canadian bank or trust company, it would not be a trust described in paragraph 150(1.2)(b). 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 9. ...