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TEI invites a summary of CRA’s discussions with HMRC in respect of large business tax compliance, including whether (1) CRA is considering implementing a cooperative compliance program for large companies in Canada; (2) benchmarking exercises were conducted (or discussed) in respect of large file audit and issue resolution practices and procedures; and (3) any formal or informal joint initiatives between the respective tax authorities are under consideration or being implemented (or expanded) in respect of large file cases. ... All exchange of information requests, whether they occur under the auspices of JITSIC or otherwise are formal treaty-based exchanges and subject to the same considerations. ... In view of the easily accessible nature of electronic records through the internet — and in consideration of the decision in the Federal Court of Appeals decision in eBay Canada Ltd. ...

Do the split income rules apply where the management of a rental property held by a trust is provided by an external property manager (unrelated to the minor) who exclusively manages the property in consideration for a percentage of the gross rents? ... (“Oka”) took part in a series of transactions in the course of which inter alia they exchanged their shares of Oka in consideration for shares in the capital of another corporation, with the shares of a particular class (the “1971 FMV Shares”) having a low PUC and an ACB equal to their FMV. ... A wishes to extract Opco surplus other than as taxable dividends: A transfers those shares to a newly-incorporate corporation (“Holdco A”) in consideration for Holdco A shares, with the transferred shares’ ACB being the agreed amount in a s. 85(1) election. ...

Question 1: Safe Income and Preferred Shares The Canada Revenue Agency (CRA) has considered the allocation of safe income to preferred shares where a shareholder acquires preferred shares in a corporation as consideration for the transfer of a property (other than shares) on a tax-deferred basis to the corporation. ... CRA Response As part of the Safe Income Paper, the CRA did state that where a shareholder acquires preferred shares of a corporation as consideration for a transfer of a property on a tax-deferred basis to the corporation, the accrued gain on the property at the time of the transfer and that would subsequently be realized by the corporation would indeed be viewed as contributing to the gain on the preferred shares and would be included in the safe income of the preferred shares. ... With respect to the nature of the financing provided by NR1 (the ultimate funder) to NR2 (the intermediary), the following considerations are relevant. ...

Implementing reporting Thus, implementing the reporting involves considerations of the timing, the scope and the conditions for use. ...

The first that come to mind are the rollover provisions where if ACB is generated, there is an immediate income inclusion, so under section 85 for example, if property is transferred and non-share consideration is received in excess of the ACB of the transferred property, that would prompt an income inclusion- so: a similar result. ...

So I throw that out for your consideration. Most people have acknowledged that 15 months is too long. ...

The guidance was careful to note that our administrative concessions in the guidance were not a promise that you would avoid Canadian residency, but rather that this new COVID situation and the restrictions on travel would be taken into consideration. ...