I’ll admit that email disclaimers are a pet peeve of mine. They seem to embody some of the less loveable characteristics of lawyers and the law. Anyway, apparently the IRS is now telling US tax practitioners to stop using “Circular…
256(6) and Indemnities
According to CRA technical interpretation 2015-0565741E5, subsection 256(6) will not save the CCPC status of a corporation whose shares are pledged to secure an indemnity. The CRA concluded that an indemnity is not a debt for the purposes of the…
More T1135 paperwork
You file your T1135 for a taxation, and for your trouble the CRA responds with a questionnaire about one of the investments shown on the form. The questionnaire requires the following information (which I have taken almost verbatim from the questionnaire itself):
Notes on Shares of a Specified Class
In applying the association rules in subsection 256(1) of the Income Tax Act (Canada), one can ignore shares of a specified class as defined in subsection 256(1.1). The CRA has said the following about that definition. Regarding the requirements in…