CRA publishes the December 2025 CTF Roundtable

26 February 2026 - 10:45pm
Email this ContentEmail this Content

The Rulings Directorate has published the official version of the December 2, 2025 CTF Roundtable. For your convenience, the table below links to the 14 questions and our summaries of them (which we published in December, with the exception of Q.12, which was first provided this week).

Topic Descriptor
2 December 2025 CTF Roundtable Q. 1, 2025-1080781C6 - Avoidance of subsection 80(3) on settlement of debt. Income Tax Act - Section 61.3 - Subsection 61.3(1) use of s. 61.3 to avoid application of s. 80(13) notwithstanding transfer of NCLs to parent, was abusive
Income Tax Act - Section 245 - Subsection 245(4) abuse to generate two losses out of the same investment
2 December 2025 CTF Roundtable Q. 2, 2025-1080681C6 - Loan Restructuring and Application of the General Anti-Avoidance Rule Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) no GAAR abuse in using tracing to convert a personal-use to investment-use loan
Income Tax Act - Section 245 - Subsection 245(4.1) structuring to convert a personal-use to an investment-use loan is not contrary to the revised GAAR
2 December 2025 CTF Roundtable Q. 3, 2025-1080671C6 - T1134 Reporting Income Tax Act - Section 233.4 - Subsection 233.4(2) - Paragraph 233.4(2)(a) once a Canadian corp has even a fleeting direct equity percentage in an FA, a T1134 reporting obligation is triggered (subject to group-filing relief) for that year
2 December 2025 CTF Roundtable Q. 4, 2025-1080661C6 - T1134 – Partnerships and the meaning of “Related Group” Income Tax Act - Section 233.4 - Subsection 233.4(4) application of group relief policy to a partnership
2 December 2025 CTF Roundtable Q. 5, 2025-1080691C6 - Intergenerational Business Transfer – control requirement in subparagraphs 84.1(2.31)(f)(i) and (2.32)(g)(i) Income Tax Act - Section 84.1 - Subsection 84.1(2.31) - Paragraph 84.1(2.31)(f) - Subparagraph 84.1(2.31)(f)(i) the continued-control test in s. 84.1(2.31)(f)(i) or (2.32)(g)(i) does not require that each member of the purchaser corp control group remain a child of the taxpayer
2 December 2025 CTF Roundtable Q. 6, 2025-1080701C6 - Intergenerational Business Transfer – Relevant Group Entity Income Tax Act - Section 84.1 - Subsection 84.1(2.31) - Paragraph 84.1(2.31)(c) - Subparagraph 84.1(2.31)(c)(iii) a related Rentalco would generally not be a relevant group entity
2 December 2025 CTF Roundtable Q. 7, 2025-1080791C6 - Treaty-Protected Business Treaties - Income Tax Conventions - Article 8 a single cross-border transport business would be required to allocate between its exempted and taxable component using arm’s length principles
Income Tax Act - Section 111 - Subsection 111(9) losses from the non-Treaty-exempted portion of a Canadian branch business may be carried over to the taxable profits of such portion in other years
2 December 2025 CTF Roundtable Q. 8, 2025-1080721C6 - Whether a Beneficiary under a Trust is Affiliated with a Corporation Controlled by the Trust Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(b) - Subparagraph 251.1(1)(b)(ii) the majority-interest beneficiary of a discretionary trust was not affiliated with a subsidiary of the trust
2 December 2025 CTF Roundtable Q. 9, 2025-1080731C6 - Subsection 191(4) and specified amount Income Tax Act - Section 191 - Subsection 191(4) specified amounts must be crystallized dollars, and a PAC can increase a redemption amount above the specified amount
2 December 2025 CTF Roundtable Q. 10, 2025-1080811C6 - Gross Negligence Penalty and Labour Requirements Income Tax Act - Section 127.46 - Subsection 127.46(9) those claiming full clean economy credits should take “reasonable steps” to ensure compliance by their subcontractors with the union labour-rate requirements
2 December 2025 CTF Roundtable Q. 11, 2025-1080761C6 - Subsection 98(5) Income Tax Act - Section 98 - Subsection 98(5) the former partnership business need not be carried on continuously throughout the 3-month period referred to in s. 98(5)
2 December 2025 CTF Roundtable Q. 12, 2025-1080801C6 - Interaction of Subsection 150(1.2) of the Income Tax Act and Subsection 204.2(1) of the Income Tax Regulations Income Tax Regulations - Regulation 204.2 - Subsection 204.2(1) an excepted trust listed in s. 150(1.2) is not subject to Sched. 15 reporting even if it is not an express trust
2 December 2025 CTF Roundtable Q. 13, 2025-1080821C6 - Expanding the Scope of Advance Income Tax Rulings General Concepts - Audit, Filing and Assessment Procedure CRA is expanding the circumstances in which it may be prepared to issue rulings on factual matters
2 December 2025 CTF Roundtable Q. 14, 2025-1080711C6 - Subsection 83(2) Election in the Context of a Subsection 84(3) Deemed Dividend Income Tax Act - Section 83 - Subsection 83(2) CRA's position, that s. 83(2) election forms and resolutions must specify dollar amounts, extends to s. 84(3) deemed dividends