Vitaliy Anissimmov of Rulings speaks at the 2014 TTPG Q&A

Highlights of CRA responses at the Toronto Tax Professionals Group Seminar held today include:

• Q.1. Swirsky has not changed the IT-533, para. 31 policy re interest on common share financings.
• Q.4. A reverse earn-out obligation of Newco, to fund its acquisition of Target, which is extinguished after Newco’s investment in Target disappears on the post-acquisition amalgamation, will be an "excluded obligation" for debt forgiveness purposes, as s. 143.4 would have operated immediately to grind the cost of the Newco shares.
• Q.5. CRA likely will apply GAAR to any future D & D Livestock situations and, more broadly, considers that GAAR generally applies to duplication of tax attributes (sounds a bit like Copthorne).
• Q.7. The 92 CMTC guidelines on choice of reporting currency still stand notwithstanding an amendment to Reg. 5907(6).

Mickey Sarazin thinks the Directorate has been giving too high a priority to technical interpretations. The pre-rulings consultation process is starting to take off.

Neal Armstrong. Summaries of 6 November 2014 TTPG Q&A and Presentation of Mickey Sarazin.