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17 July 2008 IFA Roundtable, 2008-0272361C6- Limitation of Benefits Unedited CRA Tags Art XXIX A 2(d) & (e) Principal Issues: For purposes of applying the Limitation of Benefits Provision of the Canada-US Income Tax Convention, as amended by the Fifth Protocol (the "Canada-US Treaty"), will Canada look through limited liability companies ("LLCs") and other entities that are fiscally transparent for US purposes, in applying paragraphs 2(d) and (e) of the definition of "qualifying person" of Article XXIX A? ...

Reasons: 96(1), 103 and 245(2). 2014 CTF Annual Tax Conference Canadian Tax Foundation November 30 – December 2, 2014 CRA Round Table Q.5 Streaming Partnership Income Question Does the CRA accept the streaming of certain types of income (e.g., interest income) to a particular partner of a partnership where the partnership agreement provides for such allocation? ...

Reasons: See below. 2014 CTF Conference – CRA Roundtable Q.9- 95(6)(b) Post Lehigh How will the Federal Court of Appeal decision in Lehigh Cement affect the CRA's interpretation of paragraph 95(6)(b)? ...

CTF 2010 – November 28, 2010 Reasonable Salary for Incorporated Professionals Question 21 Paragraph 1(j) of Interpretation Bulletin IT-189R2 and paragraph 17 of Information Circular 88-2 are contradictory with respect to whether a reasonable salary should be paid to an incorporated professional. ...

Reasons: Previous positions and jurisprudence. 2012 Canadian Tax Foundation Annual Conference – CRA Panel November 2012 Recent files of interest Employee "Buyco" Rulings In the late 1990s and early 2000s, advance income tax rulings were issued on transactions which were designed to allow departing employee/shareholders of private corporations to realize a capital gain, as opposed to a deemed dividend, on the disposition of their shares. ...

The estate of the deceased and other trusts funded out of the residue of the estate will generally be testamentary trusts Reasons: General comments provided- including comments from Assessing STEP CRA Roundtable – June 2012 QUESTION 8 Suppose that under the terms of a taxpayer's Will, an estate is created and the estate trustees are instructed under the Will to set up a number of trusts from the residue of the estate. ...

20 May 2009 Roundtable, 2009-0322511M6- Assignment of a T2 Refund Unedited CRA Tags 159(2), 220(6) & (7) ITA Principal Issues: Whether a U.S. resident corporation can assign its anticipated large T2 refund. ...

On October 1, 2018, the CRA published Income Tax Folio S3-F10-C3, Advantages – RRSPs, RESPs, RRIFs, RDSPs and TFSAs with a three-month comment period. ...

Unedited CRA Tags 55(3)(a), 55(2) File: 921135 Author: Simon Leung April 28, 1992 PRAIRIE TAX CONFERENCE DRAFT/EBAUCHE May 19 & 20, 1992 Question 21 Xco, which is owned 100% by Mr. ...

10 January 1992 Roundtable, 9122290- Questions au téléphone Unedited CRA Tags 3   TABLE RONDE- CGA- 10 JANVIER 1992 Agent: V. ...