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Conference summary
10 October 2014 APFF Roundtable Q. 15, 2014-0538151C6 F - 2014 APFF Roundtable, Q. 15 - Section 143.4 & Reverse Earn-out -- summary under Excluded Obligation
10 October 2014 APFF Roundtable Q. 15, 2014-0538151C6 F- 2014 APFF Roundtable, Q. 15- Section 143.4 & Reverse Earn-out-- summary under Excluded Obligation Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1)- Excluded Obligation reverse earnout obligation of Buyco re Target was excluded obligation A newly formed corporation ("Newco") purchases the shares of a target corporation ("Target") for consideration that includes an earn-out clause (resulting in a debt which is subsequently forgiven). ... However we can offer the following general comments which nonetheless, in some circumstances, would not apply in a particular situation. … … (a) …[A] reduction in the cost of the shares in the capital stock of Target through the application of subsection 143.4(2) prior to the amalgamation would in general permit the debt to qualify as "excluded obligation" as defined in subsection 80(1), by reason of the application of paragraph (a) of that definition. Paragraph (d) of the definition of "excluded obligation in general could not apply because the debt was of a capital nature. … (b) In such situations, it appears to us that in general the extinguishing of the debt could generally give rise to a "forgiven amount" given that the debt would not qualify as an "excluded obligation" as per the definition provided in paragraph 80(1).In the situations presented in this question (with ITA subsection 143.4(2) not being applicable), the fact that the shares no longer existed following the amalgamation and that consequently their cost would not be reduced, does not appear relevant to the question of there being a "forgiven amount" as defined in paragraph 80(1). ...
Miscellaneous severed letter
8 November 1989 Income Tax Severed Letter AC73828 - Integrated Sawmill & Pulpmill - M & P Deduction
8 November 1989 Income Tax Severed Letter AC73828- Integrated Sawmill & Pulpmill- M & P Deduction November 8, 1989 Carole Couin-Toussaint Rulings Directorate Director Frank Cillman Bilingual Services & Resource Industries Division 7-3828A Subject: Integrated Sawmill & Pulpmill- M & P Deduction The Special Audits Division has requested that we withdraw one of our previous opinions which states that "the transportation activity of woodchips between the sawmill and the pulpmill which occurs within an integrated operation, be included as a qualified activity within the meaning of section 5202 of the Regulations so that the capital and labour costs of transporting the chips be included in the calculation of the M & p deduction." Facts The facts which relate to that particular opinion are as follows: 24(1) The Law Subsection 125.1(1) of the Act which is the subsection authorizing the M & P deduction requires the calculation of a corporation's Canadian manufacturing and processing profits ("M & p profit") in order to determine its M & P deduction. Paragraph l25.l(3)(a) of the Act defines M & P profit by reference to rules prescribed by regulation i.e. section 5200 and following of the Income Tax Regulations ("Regulations"). ...
Administrative Policy summary
Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries" -- summary under Scientific Research & Experimental Development
Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...
Administrative Policy summary
Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries" -- summary under Scientific Research & Experimental Development
Application Policy SR & ED 96-02 "Tests and Studies Required to meet Requirements in Regulated Industries"-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...
Administrative Policy summary
Application Policy SR & ED 2002-02R "Experimental Production and Commercial Production With Experimental Development Work - Allowable SR&ED Expenditures". -- summary under Scientific Research & Experimental Development
Application Policy SR & ED 2002-02R "Experimental Production and Commercial Production With Experimental Development Work- Allowable SR&ED Expenditures".-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development ...
Technical Interpretation - Internal summary
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. ...
Administrative Policy summary
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 16. ("Constructive Importer Rules – Section 178.8") -- summary under Subsection 178.8(2)
available with membership password at http://www.cba.org/CBA/sections_NSCTS/main/GST_HST.aspx
CBAO National Commodity Tax, Customs and Trade Section – 2013 GST/HST Questions for Revenue Canada, Q. 16. ("Constructive Importer Rules – Section 178.8")-- summary under Subsection 178.8(2) Summary Under Tax Topics- Excise Tax Act- Section 178.8- Subsection 178.8(2) A resident registered corporation (Corporation A) entered into an agreement with a resident registered corporation (Supplier) for the purchase of a power facility the components of which were to be imported from abroad. ...
Current CRA website
T4088 – Scientific Research and Experimental Development (SR&ED) Expenditures Claim – Guide to Form T661
Lines 151 to 157 – Partnership information Refer to the " Partnerships " section of this guide. ... Example If out of five scientists and engineers engaged in SR&ED, one works solely on SR&ED projects and the remaining four devote only one-quarter of their working time to SR&ED, then line 632 = 1 + ¼ + ¼ + ¼ + ¼ = 2 full time equivalents (FTE)s. ... Medical and Health sciences Basic medicine 3.01.01 – Anatomy and morphology (plant science under 1.06.08) 3.01.02 – Human genetics 3.01.03 – Immunology 3.01.04 – Neurosciences 3.01.05 – Pharmacology and pharmacy and medicinal chemistry 3.01.06 – Toxicology 3.01.07 – Physiology and cytology 3.01.08 – Pathology Clinical medicine 3.02.01 – Andrology 3.02.02 – Obstetrics and gynaecology 3.02.03 – Paediatrics 3.02.04 – Cardiac and cardiovascular systems 3.02.05 – Haematology 3.02.06 – Anaesthesiology 3.02.07 – Orthopaedics 3.02.08 – Radiology and nuclear medicine 3.02.09 – Dentistry, oral surgery, and medicine 3.02.10 – Dermatology, venereal diseases, and allergy 3.02.11 – Rheumatology 3.02.12 – Endocrinology and metabolism and gastroenterology 3.02.13 – Urology and nephrology 3.02.14 – Oncology Health sciences 3.03.01 – Health care sciences and nursing 3.03.02 – Nutrition and dietetics 3.03.03 – Parasitology 3.03.04 – Infectious diseases and epidemiology 3.03.05 – Occupational health Medical biotechnology 3.04.01 – Health-related biotechnology 3.04.02 – Technologies involving the manipulation of cells, tissues, organs, or the whole organism 3.04.03 – Technologies involving identifying the functioning of DNA, proteins, and enzymes 3.04.04 – Pharmacogenomics, gene-based therapeutics 3.04.05 – Biomaterials (related to medical implants, devices, sensors) Other medical sciences 3.05.01 – Forensic science 3.05.02 – Other medical sciences 4. ...
GST/HST Ruling
19 January 2011 GST/HST Ruling 123253 - Services provided by [...] [Company A] to [...] [Company B]
19 January 2011 GST/HST Ruling 123253- Services provided by [...] [Company A] to [...] ... [Company A] [...] operates [...]. [Company A] is registered for the GST/HST. 2. On [mm/dd/yyyy], [...] entered into a [...] Agreement with [...] and on [mm/dd/yyyy] established a [...] ...
Current CRA website
Offshore Compliance Advisory Committee – Agenda – June 8, 2018
Offshore Compliance Advisory Committee – Agenda – June 8, 2018 Friday, June 8, 2018 9:00 a.m.- 4:30 p.m. ... Tax Gaps Presentation (T1 international) and follow up discussion on approach, assumptions, sensitivity analysis Mireille Éthier / André Patry / All 11:30 Lunch 12:15 7. ... Gina Jelmini / Johanne Charbonneau / All 15:45 9. Next steps / forward agenda All 16:00 10. ...