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17 May 2022 IFA Roundtable Q. 7, 2022-0926451C6- Cryptocurrency reporting Unedited CRA Tags 233.3 Principal Issues: Whether the CRA will issue guidance on when cryptocurrency is considered situated, deposited or held outside of Canada for foreign reporting requirements pursuant to section 233.3 of the Act. ...

Where a charity conducted activities through an intermediary organization (other than a qualified donee), the charity was required to maintain sufficient control and direction over the activity such that it could be considered its own activity. ...

Given that there is a tax regime in Barbados that is specific to Insurance companies, a Class 2 licensee is considered to receive a “special tax benefit” for the purposes of Article XXX(3) of the Treaty. ...

Many relevant details need to be considered in respect of each particular case and therefore it is not possible to provide specific comments on hypothetical scenarios which may be incomplete without considering all of the facts of a particular situation. ...

CALU Roundtable- May 2024 Question 12- Trust Reporting- Bare Trusts Background Pursuant to subsection 150(1.3) of the Income Tax Act (the “Act”) (endnote 1), for the purposes of section 150, a trust includes “an arrangement under which a trust can reasonably be considered to act as agent for all the beneficiaries under the trust with respect to all dealings with all of the trust’s property” (a “bare trust”). ...

However, paragraph 94(4)(c) provides that a deemed resident trust is not considered to be resident in Canada for the purposes of determining the liability of a person (other than the trust) to withhold and remit under section 215. ...

Reasons: The position set out in the Safe Income Paper is only applicable to, specifically, the transfer of property other than shares. 2024 CTF Annual Tax Conference CRA Round Table 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. ...

To the extent that the annuity payments during the lifetime of the donor are not expected to exceed the amount of the contribution, the difference will be considered to be a gift and the payments to the donor from the charity will be considered to be capital payments. ... The Halifax District Office has considered the GAAR in a number of cases. ... Question 23 AMOUNTS RECEIVABLE Subsection 12(1)(b) states that an amount must be included in income when it is considered receivable. ...

However, if it was established that Subco and Opco would not merge after the acquisition of shares, other elements may have to be considered in order to determine if subsection 245(2) would apply to the given fact situation. ... However, if Subco were not merged with OPCO following the acquisition of the shares, other elements may have to be considered in order to determine whether subsection 245(2) would apply to the Given Situation. ...

Position: General comments provided Reasons: The CRA's position is that interest income, regardless of source, is considered to be income from property for the purpose of subsection 149(5). ... Interest income, regardless of its source, earned by a club is considered income from property for the purpose of subsection 149(5) of the Act. ...