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The author of the question claims that the individuals would not be considered a group of persons in the absence of sufficient common connection between them, and that the individuals would not act in concert to control the corporations. ...

The wind-up of a retirement compensation arrangement is then an option considered by the trustee, the promoter and the employee beneficiary. ...

CRA's Response The fair market value of an interest in a life insurance policy otherwise determined and the cost of the interest in the policy must be considered in applying proposed subsection 248(35) of the Act to a gift of an interest in a life insurance policy to a qualified donee. ...

Treaty benefits claimed by an LLC with respect to an amount of income, profit or gain will be recognized by the CRA only if the amount is considered to be derived, pursuant to Article IV(6) of the Treaty, by a person who is a resident of the United States and that person is a "qualifying person" or is entitled, with respect to the amount, to the benefits of the Treaty pursuant to paragraph 3, 4 or 6 of Article XXIX A. ...

Has the CRA considered reaching out to the IRS on this matter to streamline the process of obtaining verification of credits claimed. b) Where a taxpayer performs its employment duties in a large number of U.S. states and municipalities (e.g. professional athletes), it may be very laborious and cumbersome to obtain transcripts or official notices or statements from each of the states and municipalities. ...

Assume also the following: * all transactions are part of the same series, * no safe income can be considered to contribute to the gain, if any, on the shares of Opco held by Holdco, and * paragraph 55(2.1)(b) applies to the dividend received by Holdco. ...

Despite the fact that such an LLC would not itself be required to compute its profits pursuant to U.S. tax law, and that such a computation would only be made for purposes of computing the member’s tax liability, the CRA considered this to be sufficient to bring the scenario within the scope of the above-mentioned provision. ...

Reasons: See document. 2016 CTF Annual Conference CRA Roundtable Question 8: 55(2) Fundamental Principles – Is cash a “property” for purposes of clause 55(2.1)(b)(ii)(B) Is cash considered to be property for purposes of the application of clause 55(2.1)(b)(ii)(B)? ...

2 February 2017 Quebec CPA Individual Taxation Roundtable Q. 1.6, 2016-0674861C6 F- Wholly dependent person tax credit Unedited CRA Tags 118(1)(b) Principal Issues: Can a child be considered "wholly dependent for support" on a parent for the purposes of the Wholly Dependent Person Tax Credit where the parent does not have legal custody of the child? ...

In cases where administrative relief has been provided, the apparent intent was to reduce what would otherwise be considered an undue compliance burden for the reporting entity. ...