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Simon Townsend, Silvia Wang, "Can the Hybrid Mismatch Rules Affect Canadian ULCs?", International Tax Highlights, Vol. 3, No. 1, February 2024, p. 5 -- summary under Subsection 18.4(10)

., US Parent, in the US), the Chapter 6 “deductible payments rule” does not apply if a deduction can be offset against an amount that will be included in income in both jurisdictions, so that if the interest expense can be offset against income of Cansub (which is taxed in both jurisdictions), the rule may not apply – but may apply if Cansub is in a loss position. ... Example 3: non-application of second package (p. 7) Chapter 6, which is relevant to the application of the second package, includes, in its overview, a scoping rule, which denies a deduction in the payer jurisdiction (Canada) only where the parties are in the same control group or are part of a structured arrangement – so that if this loan is not a structured arrangement, chapter 6 may not apply, and the interest deduction may not be disallowed in Canada. ...

Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709: -- summary under Tax debt

Simard-Beaudry …. With respect, the references to "debt" in this passage are consistent with the prior jurisprudence only if they are read as references to "liability. ...

Manjit Singh, Jillian Welch, "Retirement Compensation Arrangements and the Prohibited Investment and Advantage Rules", Taxation of Executive Compensation and Retirement, Special Pension Edition, Volume XVI, No. 4, 2012, p. 1041 at 1045. -- summary under Section 207.63

.] …. It appears, based on discussions with Finance, that the extension of liability to both the custodian and a specified beneficiary was considered necessary to ensure that liability for the taxes could be satisfied by all potential parties that may have benefited from the prohibited investment or advantage. ...

Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35. -- summary under Class 14

. … [CRA has ruled] that the cost of building the infrastructure asset constitutes a "cost" of acquiring the concession agreement and/or non-exclusive access licence and that these costs, as such, are otherwise included in class 14. ...

Perry Truster, "Taxable Benefits: How Much is Taxable?", Tax For The Owner-Manager, Volume 14, Number 2, April 2014, p. 2 -- summary under Subsection 15(1)

The court stated that "[i]t seems improbable that a reasonable man would charge himself for actual savings he effected through his own efforts or through a company he controlled " (emphasis added). ...

Paul Stepak, J. Scott Wilkie, "Relieving and Clarifying Changes to Canadian Bump Rules", Corporate Finance, Volume XVIII, No. 3, 2012, p. 2130 at 2132: -- summary under Subparagraph 88(1)(c.4)(ii)

Scott Wilkie, "Relieving and Clarifying Changes to Canadian Bump Rules", Corporate Finance, Volume XVIII, No. 3, 2012, p. 2130 at 2132:-- summary under Subparagraph 88(1)(c.4)(ii) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.4)- Subparagraph 88(1)(c.4)(ii) Indebtedness issued for money is specified property – this rule now confirms, from and after 2001, that indebtedness issued solely for consideration consisting of money will not generally cause a bump problem if acquired by restricted persons. ...

Paul Stepak, J. Scott Wilkie, "Relieving and Clarifying Changes to Canadian Bump Rules", Corporate Finance, Volume XVIII, No. 3, 2012, p. 2130 at 2132: -- summary under Paragraph 88(1)(c.9)

Scott Wilkie, "Relieving and Clarifying Changes to Canadian Bump Rules", Corporate Finance, Volume XVIII, No. 3, 2012, p. 2130 at 2132:-- summary under Paragraph 88(1)(c.9) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.9) References to a share in the definition of specified property includes a right to acquire a share – this rule now confirms, from and after 2001, that the right to acquire a share is assimilated to a share for purposes of the relieving definition of specified property. ...

Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50 -- summary under Paragraph 80.6(2)(c)

CRA, Income Tax Technical News no. 21 … "…in the absence of sham…a lease is a lease and a sale is a sale. ...

Allan Gelkopf, Zvi Halpern-Shavim, "Five Arbitrary Differences between Corporations and Partnerships for GST/HST Purposes", Sales and Use Tax, Federated Press, Volume XIII, No. 2, 2015, p. 674. -- summary under Subsection 186(1)

[and] Miedzi Copper … significantly expand the scope of ITC entitlement for holding corporations, although the CRA has not changed its published position, apparently on the basis that the decisions were issued under the Tax Court of Canada's Informal Procedure,...The rule under subsection 186(1) only applies to related corporations. ...

Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016 -- summary under Subsection 212.3(3)

[fn 5: The Advisory Panel on Canada's System of International Taxation, " Enhancing Canada's International Tax Advantage", 2008]…. ...

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