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However, CRA has accepted that where the trustee is clearly given the discretion to decide if the payment is to be made to a charity or to use the funds in some other manner, the payment is considered voluntary and, thus, can qualify as a gift. ...

CRA considered that the ownership requirement in para. (b) of “excluded shares,” for this purpose, is based on the actual ownership of the shares by the deceased spouse in the relevant year. ...

7 June 2019 STEP Roundtable Q. 12, 2019-0798301C6- Attribution under 75(2)-- summary under Subsection 204(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 204- Subsection 204(1) Satoma has not changed the CRA view that trusts must report income that is attributed to the settlor under s. 75(2) Under s. 75(2), income is considered to be the income of another taxpayer (the trust contributor without the income being explicitly removed from the trust itself. ...

The terms and conditions of the shared ownership arrangement, the specific life insurance contract and all other related agreements which may form part of the particular arrangement and the particular facts at the given time would have to be considered in the determination of the FMV of Opco’s interest in the life insurance policy. … The CRA does not have its own method for computing the FMV; this computation is based upon the facts known on the valuation date, to which the principles and standards of the Canadian Institute of Chartered Business Valuators are applied. ...

If there was no such agreement, repayments would be considered to be made pro rata as between the forgivable and non-forgivable portion of the loan, thereby stretching out the s. 20(1)(hh) deductions. ...

When asked about its interpretation of “reasonable error,” CRA first stated that “[f]or the error to be reasonable, it must … be considered by an impartial person to be more likely to occur rather than less likely to occur based on the circumstances of the taxpayer.” ...

In determining whether something constitutes a reasonable return, the CRA does not intend to generally substitute its judgment about what would be considered a reasonable amount where the taxpayer has made a good faith attempt to do so based on the reasonableness factors set out in the definition of “reasonable return. ...

In determining whether something constitutes a reasonable return, the CRA does not intend to generally substitute its judgment about what would be considered a reasonable amount where the taxpayer has made a good faith attempt to do so based on the reasonableness factors set out in the definition of “reasonable return. ...

CRA went on to note that it had not considered whether s. 248(1) – “disposition” – (f) or s. 107.4(3) could accord rollover treatment. ...

However, since then, there has been additional information to be considered. ...