CRA publishes the 13 May 2026 IFA Roundtable

10 June 2026 - 11:50pm
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CRA has published the official version of the questions and answers from the 13 May 2026 IFA Roundtable.

For your convenience, the table below provides links to all seven questions and to our summaries of those questions, which were prepared several weeks ago.

Topic Descriptor
13 May 2026 IFA Roundtable Q. 1, 2026-1087881C6 - Subsection 84(2) and Withholding Tax on Payments to Non-Residents Income Tax Act - Section 84 - Subsection 84(3) s. 84(3) does not apply to a payment made by Amalco to a shareholder dissenting to the amalgamation
Income Tax Act - Section 84 - Subsection 84(2) s. 84(2) generally does not apply to a payment made by Amalco to a shareholder dissenting to the amalgamation
13 May 2026 IFA Roundtable Q. 2, 2026-1087921C6 - Paragraph 95(3)(b) and Cryptocurrency Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(b) crypto (or other intangible property) is not “goods” for s. 95(3)(b) purposes
13 May 2026 IFA Roundtable Q. 4, 2026-1087931C6 - Section 116 Cash Flow Issues on Share Redemption from a Non-Resident Income Tax Act - Section 116 - Subsection 116(5) when issuing a s. 116 certificate, CRA will not require s. 116 withholding on the portion of redemption proceeds generating a deemed s. 84(3) dividend
13 May 2026 IFA Roundtable Q. 5, 2025-1078201C6 - Computation of a gain or loss for purposes of subsection 39(2) on the settlement of a foreign currency denominated debt Income Tax Act - Section 39 - Subsection 39(2) on the partial repayment of USD debt with forgiveness of the balance, the s. 39(2) gain or loss is computed on a net basis.
13 May 2026 IFA Roundtable Q. 6, 2026-1098321C6 - Foreign tax credit on U.S. tax paid on the redemption of shares of a U.S. corporation Treaties - Income Tax Conventions - Article 24 distribution from US sub that produced a capital gain arose in the US pursuant to Art. XXIV(2)(a) because it was taxed there as a dividend
Income Tax Act - Section 126 - Subsection 126(1) doubtful that Canco can claim an FTC for a US sub’s distribution that produces a capital gain but is treated under the Code as a distribution out of E&P subject to US withholding tax
13 May 2026 IFA Roundtable Q. 7, 2026-1087951C6 - Foreign tax credit and deemed year-end Income Tax Act - Section 126 - Subsection 126(1) general guidelines on how to allocate foreign tax to a short Canadian tax year for FTC purposes