CRA roundtables Q&As

Read responses from the Canada Revenue Agency (CRA) to questions posed at two 2013 roundtable discussions.

Canada Revenue Agency (CRA) officials shed light on important tax issues in response to questions posed at two recent roundtables, one sponsored by the Society of Trust and Estate Practitioners (STEP) Canada and the second sponsored by the International Fiscal Association (IFA). CRA’s official written responses for both roundtables are now available.

STEP Canada roundtable

Topics addressed at the CRA roundtable at STEP Canada’s 15th National Conference in June 2013 include:

  • “kiddie tax”
  • prescribed rate loans
  • extended reassessment period and Form T1135, Foreign Income Verification Statement
  • foreign tax credits and part-year residents
  • U.S. limited liability companies
  • price adjustment clauses
  • listed personal property
  • The Queen v Sommerer and section 75(2) of the Income Tax Act
  • probate fees and related cost base additions
  • deemed dispositions days on a trust-to-trust transfer
  • refundable dividend tax on hand and dividend refunds
  • 2012 federal budget follow-up re: CRA extending its reach through third parties, including tax practitioners
  • tax preparer registration

Read the 2013 STEP Canada-CRA Roundtable Q&A.

CRA-IFA roundtable

International tax topics addressed at IFA’s May 2013 roundtable include:

  • offshore investment funds
  • shareholder benefit rules and foreign divisive reorganizations
  • general anti-avoidance rule and losses on sales of foreign affiliate shares
  • paid-up capital planning
  • upstream loans
  • transitional foreign affiliate dumping rules
  • thin capitalization
  • new Form T1134, Information Return Relating to Controlled and Not-Controlled Foreign Affiliates
  • convertible and exchangeable debentures
  • Canada-U.S. tax treaty protocol and hybrid entities

Read the 2013 IFA-CRA Roundtable Q&A.

This document was originally prepared by a legacy CPA organization.