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28 November 2010 CTF Roundtable, 2010-0389111C6- Leveraged Donation Arrangements-- summary under Total Charitable Gifts Summary Under Tax Topics- Income Tax Act- Section 118.1- Subsection 118.1(1)- Total Charitable Gifts CRA will generally not consider advance ruling requests for leveraged donation schemes such as the one considered in Maréchaux. ...

Treaty as amended by the 5th Protocol] claimed by a fiscally transparent LLC with respect to an amount of income, profit or gain will be permitted only if the amount is considered to be derived, pursuant to Article IV(6), 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. ...

CRA responded (TaxInterpretations translation): [D]epending on the context, a deceased person could be considered as having at any time made, a loan or transfer of property, either directly or indirectly, in any manner whatever, to or for the benefit of a trust. ...

In noting that such transfers would not be considered to occur as "part of a series of periodic payments," CRA stated (Tax Interpretations translation): In general, the CRA considers that a series of periodic payments consists of at least three equal or similar payments made at regular intervals. ...

11 January 2012 STEP Roundtable, 2011-0402291C6- Subsection 248(8)-Intestacy-Transfer of Property-- summary under Subsection 70(6) Summary Under Tax Topics- Income Tax Act- Section 70- Subsection 70(6) non pro rata allocations to beneficiaries Where a taxpayer dies intestate, then provided the property of the deceased is distributed to the beneficiaries in accordance with the shares specified in the applicable provincial law of intestacy, such property will be considered to have been distributed as a consequence of the deceased's death per s. 248(8) even if each type of property is not distributed on a pro rata basis among the beneficiaries. ...

CRA responded: We agree with you that the amount of a limited partnership loss is not considered for purposes of computing the taxpayer's NCL. ...

p=37586#Q7b">19 June 2015 STEP Roundtable, oral Q.7(a)): Will an individual who becomes resident in Canada for the first time, and who has previously contributed property to a non-resident trust, thereby being considered a resident contributor, cause s. 94(3)(a) to deem the trust to be resident from January 1 of that taxation year? ...

., [1972] C.T.C. 391 at 395, 72 DTC 6354 at 6356 (F.C.T.D.) referring to "instruments for the payment of money," the questioner submitted that "segregated funds should be considered ‘securities' within the popular sense or commercial meaning of the term. ...

For example, in the case of the hobby of philately, in the past, the CRA considered that a set is a number of stamps which were produced and issued by one country simultaneously or over a short period of time. ...

5 October 2012 APFF Roundtable, 2012-0453211C6 F- Formulaire T1135-- summary under Subsection 220(3.1) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(3.1) criteria for waiver of penalties and interest In the course of a general discussion of waiver of penalties and interest for failure to timely file T1135s, CRA stated: The following four factors will be considered in the CRA's analysis to determine whether or not the penalty and interest may or may not be waived: 1. the taxpayer has, in the past, fulfilled the taxpayer’s tax obligations, 2. the taxpayer knowingly left an outstanding balance that resulted in interest on arrears, 3. the taxpayer has made reasonable efforts and has not been negligent in the taxpayer’s conduct of the taxpayer’s affairs under self-assessment regime; and 4. the taxpayer has acted diligently to remedy any delay or omission. ...