CRA Administrative Positions & Rulings of Interest | February 2019

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Please join Vitaly Timokhov on February 21st for our next installment:

In this webinar, Vitaly will discuss:

• Recent CRA Administrative Positions & Rulings of Interest

The presentation will focus on 10 recent administrative pronouncements made by the CRA that may be of interest to accountants and tax advisors. These will include the issues pertaining to the proper scope and interpretation of section 125 and ideas for preservation of business limits in the circumstances where the group of affiliated companies generates more than $50,000 in the adjusted aggregate investment income.

We will also touch on the application of subsection 125(5.2) (Anti-Avoidance) in context of tax planning efforts to multiply or preserve the small business deduction in the context of the recent Jencal Holdings case. In Jencal Holdings, the Tax Court found that the taxpayer was not entitled to claim the small business deduction because its main reason for existence was tax-motivated.