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15 September 2020 IFA Roundtable Q. 1, 2020-0853411C6 F- IFA 2020 Roundtable – T2057 & Functional Currency-- summary under Subsection 85(1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1) dual-currency filing of s. 85 elections where the transferor and transferee have different tax reporting currencies Where the parties to a s. 85 rollover transaction have different tax reporting currencies (as defined in s. 261(1)), in what currency should the amounts be reported on the form T2057? ...

3 May 2022 CALU Roundtable Q. 10, 2022-0928901C6- 2022 CALU – Q10 – Private Health Services Plan-- summary under Private Health Services Plan Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Private Health Services Plan a health spending account for a single shareholder/employee likely does not qualify as a PHSP Can a health spending account (HSA) (under which an employer agrees to reimburse its employees’ hospital and medical expenses incurred during the year up to a pre-determined limit) established for a single shareholder/employee (and family members) qualify as a private health services plan (PHSP)? CRA responded: [F]or a plan to be a PHSP … the plan must be a plan of insurance. ... Therefore, it … would likely not constitute a plan in the nature of insurance and consequently, would not qualify as a PHSP. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Subsection 5903.1(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 5903.1- Subsection 5903.1(1) FACL carryback from transitional year In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ... " See summaries under Reg. 5901(2)(b) and Reg. 5907(1) – net earnings. ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Paragraph 5901(2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b) no relief for late-filed Reg. 5901(2)(b) election In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ...

21 April 2015 Internal T.I. 2014-0560811I7- FACL carryback – Surplus & PAS election-- summary under Net Earnings Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1)- Net Earnings surplus pools are not to be retroactively adjusted for a FACL carryback In 2010, CFA paid the "2010 Dividend" to its 100% parent ("Canco"). ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Subclause 95(2)(a)(ii)(D)(I) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(D)- Subclause 95(2)(a)(ii)(D)(I) acquisition of shares that were not excluded property qualified under current use test FA Finco (a foreign affiliate of Canadian Parent) lends to FA Holdco (a Delaware subsidiary of Canadian Parent), which uses the borrowed money to acquire all of the shares of FA Target, which are not excluded property. ...

25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Subclause 95(2)(a)(ii)(D)(III) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(D)- Subclause 95(2)(a)(ii)(D)(III) in light of the current-use test, borrowed money used to acquire shares that were not excluded property could satisfy s. 95(2)(a)(ii)(D) FA Finco (a foreign affiliate of Canadian Parent) lends to FA Holdco (a Delaware subsidiary of Canadian Parent), which uses the borrowed money to acquire all of the shares of FA Target, which are not excluded property. ...

18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6- 2015 STEP – Q2 – Meaning of Graduated Rate Estates-- summary under Graduated Rate Estate Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Graduated Rate Estate one estate even if multiple wills (see also summary of initial response at 19 June 2015 STEP Roundtable, oral Q.2(a)) If an estate for a deceased who passed away after 2015 is under administration in its first 36 months, will it be considered a graduated rate estate in its entirety, even if there are two wills. ...

15 December 2006 External T.I. 2006-0182471E5 F- Intérêts " explicitement identifiés "-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) whether a court order or settlement “explicitly identifies” pre-judgment interest, so as to be taxable, is question of fact Regarding requested clarification of the position in Income Tax Technical News No. 30 that all pre-judgment interest, which is “explicitly identified” as interest in a court order or out-of-court settlement, will be taxed as interest income, CRA stated: [T]he tax treatment of pre-judgment interest explicitly identified as described in your request varies according to the specific terms and conditions of each judgment or out-of-court settlement. ...