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Reasons: The CRA would consider the classification of a foreign entity in the context of an advance income tax ruling. 2024 IFA Annual Conference CRA Roundtable Question 2 – Foreign Entity Classification The common limited partnership (société en commandite simple (SCS)) and the special limited partnership (société en commandite spéciale (SCSp)) are common types of entities used for investment funds in Luxembourg. ...

STEP CRA Roundtable – June 18 2015 Question 7- Deemed Resident Trust Question 7(a) Under the rules concerning deemed resident trusts, an individual who becomes resident in Canada for the first time, and who has previously contributed property to a non-resident trust, will be considered a resident contributor. ... A resident contributor is defined in subsection 94(1) as "a person that is, at that time, resident in Canada and a contributor to the trust …" Contributor is defined in subsection 94(1) as "a person (other than an exempt person but including a person that has ceased to exist) that, at or before that time, has made a contribution to the trust. ...

Ontario CTF Conference – October 30, 2012 Question 13 Part 1 Assume that Mr. ...

Reasons: Based on previous ITRD positions. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 9. ...

Reasons: See below. 2018 STEP CRA Roundtable – May 29, 2018 QUESTION 17. ...

Reasons: See response. 2021 CTF Annual Tax Conference CRA Roundtable Question 7 – Sub-funds and the Tracking Interest Rules in Subsections 95(8) to (12) Assume that a taxpayer owns shares of a non-resident umbrella corporation contemplated by the tracking interest rules in subsections 95(8) to (12). ...

Reasons: See below. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 3. ...

Reasons: See below. 2022 STEP CRA Roundtable – June 15, 2022 QUESTION 11. ...

Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 6. ...

Reasons: See below. 2024 STEP CRA Roundtable – June 4, 2024 QUESTION 8. ...