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Since our previous post announcing the publication of the 2026 IFA Roundtable now contains a broken link, this updated post provides a fresh link. Here is a brief summary of IFA highlights (with more detailed posts to follow next week):

• Q1: S. 84(2) generally does not apply to a payment made by an amalgamated corporation to a dissenting shareholder.
• Q2: Crypto is not “goods" for the purposes of the s. 95(3)(b) exception.
• Q3: No remittance under s. 116(5) is required for an s. 51(1) exchange.
• Q4: When a s. 116 certificate is issued for a share redemption, any remittance requirement under s. 116 will not be calculated on the portion of the redemption proceeds that is deemed to be a dividend (this, like Q.3, is a revised position).
• Q5: 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.
• Q6: CRA appears generally open to allowing a Canadian corporation to claim a s. 126(1) FTC on a distribution from a U.S. subsidiary that produces a capital gain for Canadian purposes, but is a dividend subject to 5% withholding tax for U.S. purposes, provided there is no double deduction/credit involved.
• Q7: CRA also applies a facts-based approach to determining in which Canadian taxation year an FTC can be claimed when there is a mismatch between the taxation years of Canco and of the applicable FA on whose shares US FIRPTA tax was paid.

Neal Armstrong. 13 May 2026 IFA Roundtable.