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26 November 2002 Excise Interpretation 42421 - AMENDMENT TO LETTER OF We Will Allow Administrative Pre-approval of " " Brand Cigarettes as a Prescibed Brand

26 November 2002 Excise Interpretation 42421- AMENDMENT TO LETTER OF We Will Allow Administrative Pre-approval of " " Brand Cigarettes as a Prescibed Brand Unedited CRA Tags ETA 23.3(1) XXXXX November 26, 2002 Dear XXXXX This letter is further to our previous correspondence to you of XXXXX, concerning your request to have the XXXXX brand XXXXX of cigarettes prescribed as a tobacco brand for the purposes of the export tax and tobacco marking provisions of the Excise Act and Excise Tax Act. ...

– Notice to all Excise Tax Licensees and Tax Professionals – Excise Tax Licensing and Related Enquiries

Notice to all Excise Tax Licensees and Tax Professionals – Excise Tax Licensing and Related Enquiries ETSL74 March 2010 Effective April 1, 2010 all excise tax licensing requests and related enquiries will be handled by the Excise Taxes and Other Levies Unit at Headquarters in Ottawa. ...

Canada Pension Plan and Employment Insurance Explained – Information Technology Consultants – Employees or Self-Employed Workers?

For more information, see CPP/EI Explained – Employees and self-employed workers – Responsibilities, benefits, and entitlements. ... You can find more information in paragraphs 18 and 19 of Bulletin IT73 – The Small Business Deduction. ... For information on what the Canada Revenue Agency looks at when determining the employment status of placement/employment agency workers under the Canada Pension Plan and the Employment Insurance Act, see CPP/EI Explained – Placement/Employment Agencies. ...

26 February 2025 Internal T.I. 2023-0985151I7 F - Remboursement de frais juridiques par un actionnaire à sa société / Reimbursement of legal fees by a shareholder -- summary under Incurring of Expense

A) likely could not deduct his reimbursement payment, CRA stated: … Mr. ... This court decision then eliminated any possibility of dividend income …. In short … it becomes difficult … to demonstrate the existence of a sufficient link between the expense and Mr. ...

14 June 2007 Internal T.I. 2007-0229311I7 F - Capital Dividend Account -- summary under Payment & Receipt

14 June 2007 Internal T.I. 2007-0229311I7 F- Capital Dividend Account-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt making accounting entries does not constitute payment of a dividend After noting that payment of two back-to-back capital dividends (from “Subco” to “Parentco,” and form it to its individual shareholder) had been accomplished only by accounting entries, the Directorate found that this was insufficient to give rise to a capital dividend “received” by Parentco, so that there had been no addition to its capital dividend account. In this regard, it stated: [T]he mere making of the accounting entries … does not in itself constitute the payment of a dividend … by either Subco or Parentco. … [H]owever … a dividend can be paid by a corporation and received by its recipient without any monetary movement, for example, by the issuance of a demand note that is accepted as an absolute payment by the recipient. ...

Leonard – Tax Court of Canada finds that on a foreclosure, the taxpayer disposed of his mortgage, even though the debt it secured remained outstanding

In concluding that there had been no disposition of the debt, he found that of the “four fundamental terms of a debt obligation, i.e., the identity of the debtor, the principal amount, the amount of interest and the maturity date” identified in General Electric Capital, “ the only term that was significantly different in respect of the Post-Auction Debt … was the amount of interest.” ... The key passage appears to be the following: [S]ubparagraph (b)(i) of the [s. 248(1)] definition of “disposition” … states that “‘disposition’ of any property … includes … any transaction or event by which, … where the property is a … mortgage, … the property is in whole or in part redeemed, acquired or cancelled….” … Thus, by reason of the foreclosure and the judicial sale, the Mortgage was cancelled. ... The Queen 2021 TCC 33 under s. 18(1)(b) – capital loss v. loss – debt, s. 248(1) – disposition, s. 171(1), s. 9 – timing, and General Concepts – Evidence. ...

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 3, 2020-0851991C6 F - Shares Donation to a tax exempt entity & dividend -- summary under Subsection 129(1.2)

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 3, 2020-0851991C6 F- Shares Donation to a tax exempt entity & dividend-- summary under Subsection 129(1.2) Summary Under Tax Topics- Income Tax Act- Section 129- Subsection 129(1.2) on an excepted gift of 10% of the shares of a CCPC to a public foundation and the shares’ redemption, s. 129(1.2) could deny the CCPC’s dividend refund In order to make a donation to a registered charity and public foundation (the "Donee"), a CCPC wholly-owned by Mr. ... Furthermore, the CRA took a similar approach in … 2016-0628181R3 by adding an opinion that any dividend … paid … on the shares of … the private corporation (Holdco) to the foundation (Foundation), which had previously acquired the shares as a result of the transfer of the shares by the testamentary spousal trust for the spouse of the deceased following the death of the spouse, would be considered not to be a taxable dividend, with the result that subsection 129(1. 2) would apply …. Whether the Purpose Test is satisfied is a question of fact that can only be resolved on the basis of the facts and circumstances …. ...

Ahmar – Federal Court of Appeal finds that a director’s plan to turn the company around is not a due diligence defence to failure to remit

Ahmar – before Strong Forming had to cease operations. In affirming that Mr. Ahmar had not made out the due diligence defence to director liability for failure to remit, Mactavish JA stated: … Mr. Ahmar made the conscious decision to have Strong Forming defer payment of its HST debt, and to use these revenues to satisfy other obligations in the hopes of turning the company’s financial position around. … … Buckingham … state[ed] that the defence under section 323 “should not be used to encourage such failures by allowing a due diligence defence for directors who finance the activities of their corporation with Crown monies on the expectation that the failures to remit could eventually be cured”…. ...

Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152 -- summary under Article 12

Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152-- summary under Article 12 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 12 Irishco’s purchasing a UK interest claim from Caymansco at a tax arbitrage price did not have Treaty-reduction as a main purpose BLM was a substantial Irish-resident investment company, which started acquiring proved claims in the administration of Lehman Brothers International (Europe) ("LBIE" – a UK resident) in 2011 and came to own 443 such claims. ... HMRC denied BLM’s refund claim on the basis of Art. 12(5) of that Treaty, which excluded the application of Art. 12 “if it was the main purpose or one of the main purposes of any person concerned with the … assignment … to take advantage of … Article [12].” ... “It was appropriate for the FTT to have had regard to the fact that there were potential purchasers of the SAAD Claim for whom UK WHT would not have been an issue and for whom the UK-Ireland treaty would not have been relevant [e.g., UK purchasers with tax losses] … who were prepared to pay a price higher than 80% of the interest on the SAAD Claim for reasons wholly unconnected to the UK-Ireland treaty” (para. 78). ...

Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152 -- summary under Article 7(1)

Revenue & Customs v Burlington Loan Management DAC, [2024] UKUT 152-- summary under Article 7(1) Summary Under Tax Topics- Treaties- Multilateral Instrument- Article 7- Article 7(1) accessing Irish-UK treaty dividend-withholding reduction was not abusive given that not a treaty-shopping or conduit transaction BLM was a substantial Irish-resident investment company, which had been acquiring proved claims in the administration of Lehman Brothers International (Europe) ("LBIE" – a UK resident) since 2011. ... HMRC denied BLM’s refund claim on the basis of Art. 12(5) of that Treaty, which excluded the application of Art. 12 “if it was the main purpose or one of the main purposes of any person concerned with the … assignment … to take advantage of … Article [12].” ... “It was appropriate for the FTT to have had regard to the fact that there were potential purchasers of the SAAD Claim for whom UK WHT would not have been an issue and for whom the UK-Ireland treaty would not have been relevant [e.g., UK purchasers with tax losses] … who were prepared to pay a price higher than 80% of the interest on the SAAD Claim for reasons wholly unconnected to the UK-Ireland treaty” (para. 78). ...

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