Finance Comfort Letters
Email this Content| 2019 | Link | Affected legislation | Principal topics |
|---|---|---|---|
| Dec 2 | Cross-Border Surplus Stripping & Graduated Rate Estates | s. 212.1(6)(b) | exception to s. 212.1(6)(b) look-through rule for graduated rate estates |
| Sept 4 | Principal Residence Exemption for Trusts | s. 54 – principal residence – (c.1)(iii.1)(B) | extend “principal residence” status for QDTs where an inter vivos trust |
| Sept 3 | Deductibility of Mining Taxes | s. 20(1)(v), Reg. 3900(2), s. 152(4) | removal of statute-barring where increase in mining taxes |
| Aug 26 | “Advantage”: Exclusion for Investment Management Fees | “Advantage”: Exclusion for Investment Management Fees | s. 207.01(1) definition of "advantage" and investment management fees of registered plans |
| July 29 | Eligible Capital Property (ECP) Transitional Issue | s. 14(1) eligible capital amount recognition | grandfathering of deferred proceeds from ECP disposition |
| July 29 | Functional currency tax reporting - currency of Japan | s. 261(1) definition of ‘qualifying currency” | designation of yen as qualifying currency |
| 2018 | Link | Affected legislation | Principal topics |
|---|---|---|---|
| May 11 | Saskatchewan Pension Plan - Tax Treatment of Variable Benefit Portion | s. 146(21) et seq. | variable benefits paid out of specified pension plan to qualify re pension income credits and income splitting and subject to Reg. 8506 |
| May 1 | repayment of back-to-back loans under the upstream loan rules | s. 90(14) deemed B2B loan repayment | deemed repayment of deemed loan under s. 90(7) similarly to ss. 15(2.18) and (2.19) |
| 2016 | Link | Affected legislation | Principal topics |
|---|---|---|---|
| Dec 3 | Foreign accrual property income resulting from the application of paragraph 95(2)(b) of the Income Tax Act to inter-affiliate payments for services | s. 95(2)(b)(i)(B)(I) base erosion rule | proposed extension of s. 95(2)(a)(ii)(D) safe harbor to inter-FA fees that are deemed FAPI under s. 95(2)(b)(i)(B)(I) |
| 2015 | Link | Affected legislation | Principal topics |
|---|---|---|---|
| Nov 16 | Spousal, alter ego and similar trusts | s. 104(13.4) beneficiary income inclusion | s. 104(13.4)(b) not to apply unless joint election joint election by trust and graduated rate estate and deceased died before 2017 – trust allocation of post death donations to s. 104(13.4)(a) year |
| 2014 | Link | Affected legislation | Principal topics |
|---|---|---|---|
| Dec 23 | The recent LRE amendments | s. 251.2 loss restriction events | s. 251.2(3)(f) safe harbour for unit redemptions – due date extensions for trust short year - loss restriction event only where actual beneficiary change [see also 2014-0534841C6 F] - application dates |