frequent anticipated payments and repayments occurring in a cross-border physical or notional cash-pooling arrangement likely would be a s. 15(2.6) series
Submitted by narmstrong on Mon, 06/02/2025 - 02:32
frequent anticipated payments and repayments occurring in a cross-border physical or notional cash-pooling arrangement likely would be a s. 15(2.6) series
In the course of discussion of a physical, then a notional cash-pooling arrangement between a Canadian company and affiliated foreign companies,...
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frequent anticipated payments and repayments occurring in a cross-border physical or notional cash-pooling arrangement likely would be a s. 15(2.6) series
CRA is now using s. 231.1 as its primary demand power, and is relegating s. 231.2 to special situations
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Principal Issues: Whether CRA can provide guidance on its use of the phrase “all documents and records relating to advice…received, decisions made…” in respect of requests for documents under section 231.1.
Submitted by narmstrong on Tue, 06/03/2025 - 00:15
formula for prorating foreign tax between a FAPI and non-FAPI business for FAT purposes
If a foreign affiliate (FA) carries on a business in a foreign county and pays tax to that country on income which the ITA segregates into income...
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Principal Issues: Allocation of deductions allowed under foreign law between the active business and the FAPI-generating business of a foreign affiliate for the purpose of determining the amount of foreign tax that is FAT applicable to the FAPI of the foreign affiliate.
Position: Foreign deductions should first be allocated to income from an activity to which they may reasonably be regarded as applicable.
Reasons: The language in the FAT definition in subsection 95(1) requires an allocation of foreign tax to FAPI on reasonable basis.
Submitted by narmstrong on Tue, 06/03/2025 - 00:40
the opening UCC for used depreciable property of an acquired LLC for the first year of computing its (a)(iii) earnings was the lesser of UCC and FMV
A US LLC, which was formed in 2017 by a regarded US corporation, acquired and used appreciable assets in carrying on its active business in the US...
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Principal Issues: In the facts outlined, for purposes of determining US LLC’s 2024 earnings from its active business in accordance with regulation 5907(2.03), should the maximum CCA be considered to have been claimed by US LLC for the 2017 to 2023 taxation years?
