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CRA indicates that the flipped property rule may not apply where a beneficiary receives the devise of a house of a deceased parent and promptly sells it

21 March 2024- 11:04pm CRA indicates that the flipped property rule may not apply where a beneficiary receives the devise of a house of a deceased parent and promptly sells it Email this Content Although s. 13(12) deems the gain of a taxpayer from the disposition of a housing unit within 365 days of its acquisition to be an inventory gain, s. 12(13)(b)(i) provides an exception for a disposition which inter alia can reasonably be considered to occur due to the death of a person related to the taxpayer. ...

CRA indicates that worker’s compensation received by an estate was includible in its income

However, CRA noted: [A]s compensation payments are not considered salary, wages, or other remuneration, they are not subject to the withholding of income tax, Canada Pension Plan contributions, and Employment Insurance premiums, irrespective of the recipient. ...

CRA indicates that the salary of a status Indian from his corporation may be exempted based on the relative sourcing of its income on and off reserve

CRA indicated that although this was a question of fact, it might be considered that since 70% of the corporation's business income was located on a reserve, 70% of the physician’s salary from his corporation should be exempted. ...

CRA confirms its policy in IT-244R3 regarding gifts of a life insurance policy to a charity, but does not articulate any extension of this policy to split dollar arrangements

7 July 2024- 10:20pm CRA confirms its policy in IT-244R3 regarding gifts of a life insurance policy to a charity, but does not articulate any extension of this policy to split dollar arrangements Email this Content IT-244R3 indicated that a gift by an individual of a life insurance policy to a registered charity is considered to be a gift for purposes of s. 118.1 provided that the policy has been absolutely assigned to the donee, who becomes the registered beneficiary. ...

Foix – CRA reiterates that Foix overruled a more restrictive approach to s. 84(2) in some earlier cases (and restricts Geransky)

Now, in brief oral comments when a question about this case was repeated, CRA indicated: the reasons in Foix should be carefully considered in connection with any proposed hybrid sale (with exception of transactions identical to those in Geransky); the decision reinforces the broad scope of s. 84(2); and it represents a departure in some respects from the more restrictive view of s. 84(2) evident in some earlier cases. ...

CRA confirms that it is the bare trustee rather than the beneficial owner who has any UHT filing obligations

., the individual was not a person that “could reasonably be considered to be an owner in respect of the residential property based on [the land registry] system” under the definition of owner. ...

CRA finds that delivery services supplied to a platform, which had contractual responsibility for the delivery to the purchasing consumer, were zero-rated

In particular, CRA indicated that “[f]or a person to be considered a 'carrier', the person need only assume liability as a supplier of a freight transportation service,” so that the platform was the first carrier even though it did not do any of the transporting. ...

CRA notes that a supplementary disability plan for the company’s majority shareholder and another executive might not qualify as a s. 6(1)(a)(i) group plan

CRA indicated that if there was “a higher level of benefits for the employee who is the majority shareholder compared to the level of benefits for the other employee in the group, such a policy would probably not be considered a component of a group insurance plan, but rather an individual disability insurance policy.” ...

Using a secondment arrangement may reduce complications when a non-resident provides the services of an employee to a Canadian affiliate

27 September 2015- 8:06pm Using a secondment arrangement may reduce complications when a non-resident provides the services of an employee to a Canadian affiliate Email this Content A non-resident who is assigning one of its non-resident employees to Canada may be able to avoid setting up a payroll account with CRA, and being considered to carry on business in Canada, by "seconding" (loaning out) the employee to its Canadian affiliate (Canco) in accordance with the IC-75-6R2 guidelines, so that Canco is treated by CRA as the employer and is "responsible" for the Canadian source deductions – even though the employee stays enrolled with the non-resident’s pension, equity compensation and other benefit plans. ...

Canadian investors in an LLP viewed as a U.S. corporation generally should not be entitled to U.S. Treaty benefits on U.S. source income of the LLP

If a LLP or LLLP (viewed by CRA as a U.S. corporation) were subject to Canadian corporate tax by virtue of being considered to have a Canadian permanent establishment, the U.S. should permit the U.S. partners foreign tax credits for the tax to the same extent as if the LLP/LLLP were regarded as a partnership in Canada. ...

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