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The taxation of participants in the year in which contributions are made to an EPSP (in contrast to an EBP trust whose participants are not taxable regarding contributions to or earnings of the trust until they receive a distribution) means that EPSPs will usually be most useful in connection with employee share plans under which the contributions are relatively small. ...

XIII tax to premiums paid by non-resident corporation 22 May 2001 External T.I. 2000-0047245 F- Divorce Income Tax Act- Section 251- Subsection 251(1)- Paragraph 251(1)(c) reciprocal transactions completed after divorce would be non-arm’s length Income Tax Act- Section 84.1- Subsection 84.1(1) sale of ex-wife’s shares of Opco (acquired in marriage settlement) to new Holdco of her ex-husband for Holdco note would engage s. 84.1 if these were “reciprocal transactions” 29 May 2001 External T.I. 2000-0055915 F- DEDUCTIBILITE DES COMMISSIONS- ASSURANCE Income Tax Act- Section 18- Subsection 18(9.02) background to s. 18(9.02) 25 May 2001 External T.I. 2001-0067415 F- CONSOLIDATION DE PERTES Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) related-person loss transfer transactions must be commercially reasonable to satisfy s. 20(1)(c) Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(a) CCRA loss consolidation policy is available where Profitco’s income is FAPI/ requirements re transactions being commercially reasonable 29 May 2001 External T.I. 2001-0075245 F- SOCIETE DE GESTION DE PENSION Income Tax Act- Section 149- Subsection 149(1)- Paragraph 149(1)(o.2)- Subparagraph 149(1)(o.2)(i) s. 149(1)(o.2)(i) corporation can be incorporated for the administration of more than one RPP – but cannot be incorporated to provide management services to other RPPs Statutory Interpretation- Interpretation Act- Subsection 33(2) reference to administration of one pension plan included two or more 23 May 2001 External T.I. 2001-0077855 F- PLACEMENT ADMISSIBLE REER Income Tax Regulations- Regulation 4900- Subsection 4900(8) did not extend to services rendered in connection with the company’s incorporation ...

Exception Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares investment business a business for excluded share purposes Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Amount- Paragraph (e)- Subparagraph (e)(i) “derivation” for TOSI purposes of dividends from previously earned income from a related business 27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares exclusion for investment business or passive amounts not derived from a related business 27 November 2018 CTF Roundtable Q. 11, 2018-0779971C6- Record Retention Policy Guideline Income Tax Act- Section 232- Subsection 232(1)- Solicitor-Client Privilege solicitor-client privilege does not extend to list of uncertain tax positions Income Tax Act- Section 231.1- Subsection 231.1(1) in some circumstances CRA considers that it can require a taxpayer to disclose its uncertain tax positions 27 November 2018 CTF Roundtable Q. 12, 2018-0785021C6- Investment management fees 27 November 2018 CTF Roundtable Q. 13, 2018-0779991C6- 20(1)(c) & Triangular Amalgamation Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on money borrowed by parent for use in connection with a triangular amalgamation to redeem preferred shares issued by Target can be deductible 27 November 2018 CTF Roundtable Q. 14, 2018-0779911C6- Foreign exchange Income Tax Act- Section 20- Subsection 20(14) accrued interest translated on transfer date Income Tax Act- Section 261- Subsection 261(2)- Paragraph 261(2)(b) accrued interest under both ss. 20(14)(a) and (b) is translated at the transfer date spot rate 27 November 2018 CTF Roundtable Q. 15, 2018-0780011C6- Class 14.1 Income Tax Act- Section 13- Subsection 13(35)- Paragraph 13(35)(a) capital expenditures not giving rise to property are deemed to be goodwill property Income Tax Regulations- Schedules- Schedule II- Class 14.1 Class 14.1 “property” need not be property 27 November 2018 CTF Roundtable Q. 16, 2018-0780031C6- 2018 CTF- Q16- Passive Income Reduction Rules Income Tax Act- Section 125- Subsection 125(5.1)- Paragraph 125(5.1)(b) effective date of the passive income rules for non-calendar year associated corporations ...

To illustrate the disproportionate nature of the automatic penalty under s. 231.7(6), consider a corporation which provided 95 out of 100 documents requested regarding an audit of three taxation years, and claimed solicitor-client privilege for the other 5 documents and, in connection with CRA seeking a compliance order, the Federal Court determines that there was insufficient evidence to establish that two of the documents were privileged: even though the corporation was substantially compliant, it is subjected to the penalty of 10% of its tax for the three years. ...