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While acknowledging these comments, CRA indicated that they are 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. ...

In addition, the tax consequences under paragraphs 84.1(1)(a) and 84.1(1)(b) will apply only if the shares of the capital stock of Target had an increase in value prior to 1971 or a capital gains deduction was claimed by the individual or a person not dealing at arm's length with the individual in connection with a previous disposition of the shares of the capital stock of Target. ...

2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F- APFF- Congrès 2023- Table ronde sur la fiscalité-- summary under Subsection 69(4) Summary Under Tax Topics- Other Legislation/Constitution- Federal- Bankruptcy and Insolvency Act- Section 69- Subsection 69(4) where a contested notice of assessment is subject to a stay, it generally must apply to the bankruptcy court for lifting the stay Trustee of Girard, 2014 QCCA 1922, stated, in connection with the Bankruptcy and Insolvency Act ("B.I.A. ...

29 August 2023 CPAC Roundtable Q. 8, 2023-0983051C6- Automobile Expenses-- summary under Paragraph 8(1)(h.1) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(h.1) Gardner (re deducting a sales person’s expenses of occasional travel between her home office and her employer) will be followed only on similar facts Regarding the deductibility of automobile expense incurred by an employee, with a fully remote work arrangement, in connection with an occasional visit to the office from the home office, CRA stated: [T]raveling between an employee’s home, including a home office, and a regular place of employment (RPE) is generally considered personal travel …. … In this case, “regular” means there is some degree of frequency or repetition in the employee’s reporting to that particular location in a given pay period, month, or year. … For example, a work location may be considered to be a RPE of an employee even though the employee may only report to work at that particular location on a periodic basis (e.g., once or twice a month) during the year. ...

A, in connection with the estate freeze carried out by Mr. A. in favour of Initial Trust, if the Purpose Test were satisfied. ...

Regarding GAAR, CRA would look for a sufficient connection between the deceased person and the property that is being distributed and the specified individual to support the application of the deeming rule in these circumstances. ...

What actions has Parent taken in connection with the reduction in value of the shares of the capital stock of Target? ...

After noting that this ERDTOH-NERDTOH shift resulted “from the fact that paragraph 186(1)(b) makes no connection between the type of RDTOH account entitling Aco to the DR and the type of dividend received by Bco and Cco,” CRA agreed that, here, “the conversion of an amount of ERDTOH into an amount of NERDTOH results in an increase in the tax payable by the Shareholder … but only at … the stage where the amount of dividends paid is limited to the amount necessary to give entitlement to the DR of the ERDTOH and the NERDTOH of Bco and Cco totalling $138,333.” ...