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2012 Ruling 2012-0435211R3- Article XXIX-A(3) of the Canada-US Tax Convention-- summary under Article 29A Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29A US Holdco in Chap. 11 receives dividend Holdco, which had been a listed U.S. company, was taken private by L5, which is a fund whose members are not known. ...

Convention-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 test of a real property security under the Canada-U.S. ...

17 May 2023 IFA Roundtable Q. 4, 2023-0965421C6- Canada-Barbados Income Tax Convention – “Special Tax Benefit”-- summary under Article 29 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 29 Class 2 licensees under the Barbados Insurance Act receive a “special tax benefit” for purposes of the Treaty-benefit exclusion Art. ...

29 March 2006 Internal T.I. 2006-0171171I7 F- Convention de retraite-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement plan was not an RCA because benefits were unreasonable A plan set up to provide benefits to officers of a corporation was not a retirement compensation arrangement (RCA) since the benefits to be paid were not reasonable in the circumstances. ...

2 May 2001 Internal T.I. 2001-007939 F- CONVENTION D'EMISSION D'ACTIONS-- summary under Subsection 7(2) Summary Under Tax Topics- Income Tax Act- Section 7- Subsection 7(2) whether s. 7(2) applied turned on whether shares were held as trustee After providing an overview of s. 7(2), the Directorate noted that in this case whether it applied turned on a factual determination of whether shares were held by a person as trustee. ...

28 November 2003 External T.I. 2003-0046025 F- CONVENTION DE RETRAITE DEDUCTIONS-- summary under Paragraph 20(1)(r) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(r) s. 20(1)(r) deduction is limited by s. 67 CRA indicated that the deduction under s. 20(1)(r) could be limited by s. 67 and that there was nothing in s. 152(3.1) that would restrict its application to the s. 20(1)(r) deduction. ...

20 August 2008 External T.I. 2008-0288561E5 F- Convention de partage d'une société de personnes-- summary under Subsection 103(1) Summary Under Tax Topics- Income Tax Act- 101-110- Section 103- Subsection 103(1) CRA generally does not challenge sharing agreements based on each partner’s contribution After indicating that an agreement to allocate income to a retired partner generally would be respected but for there being no partnership net income, CRA went on to state: Generally …CRA … does not question the validity of a partnership sharing agreement that is based on the contribution of each partner. ...

29 March 2006 Internal T.I. 2006-0171171I7 F- Convention de retraite-- summary under Section 67 Summary Under Tax Topics- Income Tax Act- Section 67 application of a version of the Gabco test Amounts paid to a trust governed by a retirement compensation arrangement (RCA) were non-deductible in computing the corporation's income on the basis that the amounts paid were not paid to earn income and were not reasonable in amount. ...

16 October 2003 External T.I. 2003-0038315 F- CONVENTION DE RETRAITE-- summary under Retirement Compensation Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement loan back to employer may negate RCA status An RCA trust created for the benefit of a managing shareholder and to which the employer contributed $100,000 lends the amount of the contribution, net of refundable taxes (i.e., $50,000), to the corporation. ...

14 January 2004 External T.I. 2003-0046131E5 F- Convention de retraite- dépositaire-- summary under Subsection 207.6(2) Summary Under Tax Topics- Income Tax Act- Section 207.6- Subsection 207.6(2) employer is deemed custodian under s. 207.6(2) After indicating that a life insurance company can be a custodian of a "retirement compensation arrangement" (“RCA”), CRA went on to state: Subsection 207.6(2) sets out special provisions where an employer acquires an interest in a life insurance policy for the purpose of enabling the employer to fund benefits to be received by an employee upon or after retirement. ...