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26 May 2016 IFA Roundtable Q. 2, 2016-0642061C6- AOA & Notional Expenses CRA Tags Treaties Article VII Principal Issues: Whether notional expenses determined under the AOA and attributable to a taxpayer’s permanent establishment in Canada can be deducted for Canadian tax purposes? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 2 – Authorized OECD Approach to Profit Attribution The possibility of deducting notional expenses in determining the profits attributable to a permanent establishment (“PE”) of a non-resident under Canada’s tax treaties was seemingly put to bed by the 1998 decision of the Federal Court of Appeal in Cudd Pressure (footnote 1). ... In respect of the Canada – United Kingdom Tax Convention, we would note that the new AOA-based Article 7 language was included in the convention by virtue of the protocol signed on July 21, 2014. ...

STEP CRA Roundtable – June 18, 2015 Question 14. Requirements for Question #6 on page 2 of the T3 Return Question 6 of the T3 return reads as follows: Did the trust borrow money, or incur a debt, in a non-arm's length transaction since June 18, 1971? ... The instructions for question 6 refer the reader to Interpretation Bulletin IT-406R2 – Tax Payable by an Inter Vivos Trust (the "IT"). ... Reference may be made to Folio S1-F5-C1 – Related persons and dealing at arm's length, for discussion as to the meaning of the term "at arm's length". ...

LLPs & LLLPs CRA Tags 248(1) "corporation" Principal Issues: Whether LLPs and LLLPs governed by the laws of Florida or Delaware would generally be treated as corporations for the purposes of the Act? ... Reasons: The provisions of the foreign legislation and the articles creating these entities support the general conclusion that these types of entities should generally be treated as corporations for the purposes of the Act. 2016 International Fiscal Association Conference CRA Roundtable Question 1 – Entity Classification: U.S. ... The main factors we considered in our analysis of these entities are the existence of a separate legal personality that is recognized under the law of the relevant foreign jurisdiction – meaning the full legal capacity to acquire and own property, to sue and be sued, to carry on their own activities and to incur liabilities of their own – and the extensive limitation of liability afforded to all of their members. ...

10 June 2013 STEP CRA Roundtable, 2013-0480301C6- 2013 STEP CRA Roundtable – Question 4 CRA Tags Treaties Article XXIV 126(7) "non-business-income tax" 20(11) Treaties Article V Principal Issues: What credits and deductions are available to U.S. citizens resident in Canada on taxes paid in respect of dividend income now that rates have increased in conjunction with the "fiscal cliff". ... Reasons: Text of the treaty. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 4. ...

10 June 2013 Roundtable, 2013-0480411C6- STEP Roundtable – June 2013- Question 10 Principal Issues: Deductibility of probate and related fees by an estate. Position: Question of fact Reasons: In our view, the Tax Court of Canada's decision under the informal procedure was based on the unique facts of the case. 2013 STEP CANADA ROUNDTABLE, June 10 & 11, 2013 QUESTION 10. ...

26 May 2016 IFA Roundtable Q. 7, 2016-0642121C6- 93(2.01) & Capital Contribution CRA Tags 93(2) 93(2.01) Principal Issues: Whether the concept of “substituted shares” used in subsection 93(2.01) may be interpreted in such a way as to refer to shares owned by a taxpayer in respect of which the taxpayer made a capital contribution consisting of shares of another foreign affiliate? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 7 – Subsection 93(2.01) substituted property rule and capital contributions Assume the following hypothetical facts: a) Canco owns all of the shares of each of FA1 and FA2. b) Canco capitalizes FA1 with $1,000 of equity. c) FA1 loans $1,000 to FA2 for use in its active business. d) A few years later, after having paid dividends of $50 to Canco, FA1 becomes a wholly-owned subsidiary of FA2 as a result of a contribution of capital by Canco of the shares of FA1 to FA2. ...

13 February 2017 Roundtable, 2017-0684491C6- CPA-BC & CRA Roundtable 2017 Principal Issues: Whether the CRA will re-introduce a dedicated phone line for tax professionals. ... CPA-BC & CRA Roundtable 2017 Question 16: We were very excited about the introduction of the CRA’s “professional designated phone line”, only to find out that this was meant for small practitioners who have no tax advisers. ...

25 September 2012 CTF Roundtable Q. 4, 2012-0457581C6- CTF BC – Q4 Residency of a Trust Principal Issues: Impact on the CRA published position in relation to the factors it considers indicative for purposes of establishing residency of a trust in light of the 2012 SCC decision in St. ... Reasons: Comments as previously published by the Directorate British Columbia Tax Conference September 25, 2012 Question 4 – Residency of a Trust for Tax Purposes CRA's long-standing position on the determination of the residency of a trust for tax purposes is described in IT-447 Residence of a Trust or Estate (published in 1980). ...

26 May 2016 IFA Roundtable Q. 10, 2016-0642101C6- 93.2 & 95(2)(c) CRA Tags 93.2 Principal Issues: Whether paragraph 95(2)(c) applies in a situation where a taxpayer transfers shares of a foreign affiliate to another foreign affiliate that is a “non-resident corporation without share capital”, within the meaning of subsection 93.2(1), without any “shares” being issued as consideration? ... Reasons: See below. 2016 International Fiscal Association Conference CRA Roundtable Question 10 – Interaction of section 93.2 and paragraph 95(2)(c) It is our understanding that subsection 93.2(3) was introduced with the specific purpose of facilitating the application of paragraph 95(2)(c), among other provisions, to “non-resident corporations without share capital”, within the meaning of subsection 93.2(1). ...

10 June 2016 STEP Roundtable Q. 4, 2016-0645801C6- QDT & pref beneficiary election CRA Tags 108(1) Principal Issues: 1. ... STEP CRA Roundtable – June 10, 2016 Question 4. Qualified Disability Trust and Preferred Beneficiary Election There are a number of conditions that must be met in order for a trust to be eligible to be a Qualified Disability Trust (“QDT”) for a particular tax year. ...