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Glen Loutzenhiser, "Sham in the Canadian Courts", Sham Transactions (Edwin Simpson and Miranda Stewart, editors), Oxford University Press, 2014. -- summary under Sham

. … [T]he court held the transaction was not a sham because it was not constructed to create a false impression-the appearance created by the documentation was the reality…. ... Noël JA concluded that on that basis the filings were a sham. … The classic Snook formulation of a sham requires a common intention that the acts or documents are not to create the legal rights and obligations which they give the appearance of creating. ...

Carrie Smit, "Repurchasing Underwater US Dollar Notes", International Tax (Wolters Kluwer), August 2015, No. 83. -- summary under Subsection 39(3)

Unfortunately, the issuer may not be able to apply the foreign exchange loss to offset a portion of the forgiven amount… Comparison with open market purchase]T]he capital gain realized under subsection 39(3) is equal to the excess of the amount for which the obligation was issued over the purchase price to be paid....CRA...has taken the position [fn 4: … 2008-0302511I7....]… that the amount for which the obligation was issued, and the purchase price to be paid, need to be translated into Canadian dollars using the relevant exchange rates at the times such amounts arose. ...

Brent F. Murray, "The General Anti-Avoidance Rule: CRA Discussions on GST Matters", CCH Tax Topics, No. 2191, March 6, 2014, p. 1. -- summary under Subsection 274(4)

CRA misconcepton that no GST avoidance (p. 2) In an internal presentation from the Compliance Programs Branch...that was prepared in September 2006, it was indicated that "misconceptions exist at all levels that tax avoidance does not exist in relation to the Excise Tax Act "…. ...

Steve Suarez, "Canada's 88(1)(d) Tax Cost Bump: A Guide for Foreign Purchasers", Tax Notes International, December 9, 2013, p. 935 -- summary under Subparagraph 88(1)(c.2)(i)

Ownership of Shares in Related Upstream Corporations: a person is deemed to be a specified shareholder of a particular corporation if that person meets the 10 percent share ownership (or deemed share ownership) threshold in any other corporation that both: is related to the first corporation; and has a ''significant direct or indirect interest'' in the first corporation — that is, an ''upstream'' related corporation. ...

Henry Chong, "Canada and FATCA", Tax Management International Journal, 2014, p. 527. -- summary under Section 2

. … [I]nvestment vehicles such as private trusts that do not hold themselves out to the public as investment funds would not appear to be included as Financial Institutions or RCFIs under the expanded definition of that term under the Act but could be RCFIs under the Canada FGA and FFIs under FATCA. ...

Justice Marshall Rothstein, "An Overview of the Supreme Court of Canada", Bulletin for International Taxation (IBFD), January/February 2016, p. 20. -- summary under Stare Decisis

.-- summary under Stare Decisis Summary Under Tax Topics- General Concepts- Stare Decisis Stare decisis usually applies (p. 20) As the Court recently noted: " stare decisis is not a straitjacket that condemns the law to stasis". ...

Paul Dhesi, Korinna Fehrmann, "Integration Across Borders", Canadian Tax Journal, (2015) 63:4, 1049-72 -- summary under Subsection 93(1)

[T]he overall flow-through tax result can be improved if a purchaser is willing to acquire the shares of the CFA | rather than the asset directly. ...

Ian Crosbie, "Recent Transactions of Interest, Part I", 2015 CTF Annual Conference paper -- summary under Subsection 212.3(2)

. … 2) [A]t the same time, a) In consideration for shares in the capital of Whiting (the "consideration") delivered to the Kodiak shareholders by Whiting on behalf of Whiting Bidco, Whiting Bidco issued shares to Whiting with a fair market value equal to the value of the consideration; and b) Whiting Bidco purchased the outstanding Kodiak shares in exchange for the consideration, to be issued directly by Whiting to Kodiak shareholders on behalf of Whiting Bidco…. 5) Whiting Bidco and Kodiak amalgamated (to form "Kodiak Amalco") "with the same effect as if they were amalgamated under...the BCBCA", "except that the separate legal existence of [Kodiak] will not cease and [Kodiak] will survive the Amalgamation". ...

Christian Ehlermann, Marla Castelon, "When Does a Dependent Agent Act Habitually?", Tax Notes International, 26 September 2016, p. 1141 -- summary under Article 5

", Tax Notes International, 26 September 2016, p. 1141-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Proposed change in BEPS final action plan to agency PE effectively elevates "habitually" requirement (p. 1142) [A]rticle 5(5) will no longer require the dependent agent to conclude contracts in the principal's name; it will be sufficient that the dependent agent habitually plays the principal role leading to the routine conclusion of contracts without material modification by the enterprise — that is, the principal. ...

Doron Barkai, Alexander Demner, "Dealing with New Subsection 55(2): Issues and Strategies", 2016 Conference Report (Canadian Tax Foundation), 6:1–56 -- summary under Paragraph 55(2.1)(b)

. … [T]he court did analyze the reduction in the FMV of the shares (which is essentially the new FMV-reduction purpose test) and concluded that such a reduction, in a creditor-proofing transaction, was one of the effects of the transaction, but not one of its purposes… …However, the CRA could theoretically argue that the cost-increase purpose test is applicable with respect to creditor-proofing transactions. ...

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