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7 May 2024 CALU Roundtable Q. 8, 2024-1007121C6- IPPs & Past Service Contributions-- summary under Subsection 8303(6) Summary Under Tax Topics- Income Tax Regulations- Regulation 8303- Subsection 8303(6) a RRIF may not make a Reg. 8303(6) qualifying transfer to a RPP in connection with a past service event Where an individual pension plan (IPP) as defined in Reg. 8300(1) is established and a plan member is age 71 in the effective year of the plan, would CRA allow the qualifying transfer which is required as part of a past service contribution (typically satisfied by a transfer of the required asset value from a registered retirement savings plan) to be satisfied by the transfer of the required asset value from a registered retirement income fund (RRIF)? ...

(c) The type of connection a device uses (i.e. wired vs. wireless) does not determine whether it is ancillary data processing equipment. ...

(which would not normally be the case where the partnership was merely holding shares or interests in a wholly-owned subsidiary), (ii) the loan was incurred in connection with such permanent establishment and (iii) the interest paid on the loan was borne by such permanent establishment. ...

As such any payments in respect of the copyright of a literary, dramatic, musical or artistic work, including the right in respect of the translation, performance, telecommunication or broadcast of one of the aforementioned works will not be subject to withholding tax unless that payment is for a right in or the use of a motion picture film or a film or video tape for use in connection with television that is to be used or reproduced in Canada. ...

CRA responded (TaxInterpretations translation): The definition of "RRIF" in section 146.3 expressly…requires the holding of a SIN in connection with the registration of a RRIF. ...

9 October 2015 APFF Roundtable Q. 9, 2015-0595661C6 F- Question 9- Table Ronde APFF 2015-- summary under Paragraph 20(1)(m) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(m) s. 20(1)(m) reserve may be claimable for an amount included under s. 9 rather than 12(1)(a) Distributors received up-front payments from a manufacturer for their agreement to provide services in connection with promoting the manufacturer's products. ...

In connection with the disposition of a taxpayer's shares, a structure involving a family trust and the participation of accommodation parties is implemented in order to avoid tax on the capital gain resulting from the disposition of the shares through the use of the capital gains deduction. ...

.; the income is “derived from [Canada] in connection with, or incidental to, that trade or business (including any such income derived directly or indirectly by [the U.S. resident] through one or more other [Canadian residents] (the “connected test”); and the trade or business carried on in the U.S. is substantial in relation to the activity carried on in Canada giving rise to the income in respect of which treaty benefits are claimed- the connected test will not be satisfied. ...

However, CRA indicated that these comments were not specifically directed at the T3 return, which is a return of information (in addition to a return of income) affecting the taxation of persons with some connection to the trust. ...

. … The postponement or cancellation of a project does not alter the nature of an expense incurred in connection with such project. ...