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In Scenario 1, the exchange rate of the US dollar is US $1 = CDN $1 at Time 1 and US $1 = CDN $1.2 at Time 2 At Time 2 Can Opco pays a dividend of $120 to Can Holdco In Scenario 2, the exchange rate of the US dollar is US $1 = CDN $1.2 at Time 1 and US $1 = CDN $1 at Time 2 At Time 2 Can Opco pays a dividend of $100 to Can Holdco. ... Regarding the first question, a similar question was asked at the 2005 APFF Roundtable. ... This implies a degree of correlation or direct substitution – one might say a “causal relationship” – between the disposition of the former property and the acquisition of the new one. ...

Email this Content 27 October 2020 CTF Roundtable Q.1 – ACB increase in s. 55(3)(a)/88(1) reorg Preliminary Response Official Response Q.2 – Consolidation of safe income in a corporate group Preliminary Response Official Response Q.3 – Safe Income on Reorganization Preliminary Response Official Response Q.4 – Sale of taxable Canadian property by a partnership Preliminary Response Official Response Q.5 – Art. ... Treaty where further French layer Preliminary Response Official Response Q.6 – MLI and PPT Preliminary Response Official Response Q.7 – Use of cottage by children of settlor of AET/JST/CLPT Preliminary Response Official Response Q.8 – SDA rules and formula-based appreciation plans Preliminary Response Official Response Q.9 – UK LLPs as corporations Preliminary Response Official Response Q.10- Refreezes and s. 74.4(2) attribution quantum Preliminary Response Official Response Q.11 – Refinancing prescribed rate loans and attribution Preliminary Response Official Response Q.12 – Impact of COVID-19 on Previous APAs/Current MAPs Preliminary Response Official Response Q.13 – Reimbursement of Equipment Preliminary Response Official Response Q.14 – Section 86 Reorganization of Capital Preliminary Response Official Response This provides the text of the written questions that were posed, and summaries of the CRA oral responses, at the CRA Roundtable webinar hosted on 27 October 2020 by the Canada Tax Foundation. ... Last, but not least, the CRA supports that policy through the administration of the GAAR which was clarified back in 2005 as retroactively applying in treaty situations. ...