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Article Summary
Nik Diksic, Sabrina Wong, "Cross-Border Lending Practices", 2017 CTF Annual Conference draft paper -- summary under Subparagraph 20(1)(c)(i)
M & L Leasing, 2000 ABQB 714] ...
Article Summary
Joint Committee, "Hybrid Mismatch Arrangements Proposals", 30 June 2022 Submission of the Joint Committee -- summary under Subsection 227(6.1)
Proposed Paragraph 20(1)(yy) & Dividend Withholding Tax”) Where s. 18.4(4) denies a deduction for an amount paid as interest, s. 214(18) deems such amount to have been paid as a dividend for Part XIII purposes. ...
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Brooke Sittler, "Review of Penalty and Interest Relief Requests Under the Income Tax Act", 2015 CTF Annual Conference paper -- summary under Subsection 220(3.1)
See also Cogesco... 2013 FC 1238 at paras 18-20... and 3500722 Canada... 2008 FC 554....] the Federal Court allowed the application for judicial review on the basis that the court was unable to determine on the record whether the CRA considered certain facts that the court considered relevant: … In the early years of the administration of subsection 220(3.1), it was more common for the Federal Court to find a lack of independence within the CRA during the process of subsequent reviews. ... Limited nature of relief (p. 42:10-11) The Federal Court of Appeal in Slau confirmed that in allowing an application for judicial review, it is not open to the reviewing court to mandate an outcome where more than one is possible: … The limited remedy that a reviewing court can give in taxpayer relief cases is outlined by the Federal Court in Kapil: As a matter of law, this Court does not have the jurisdiction to order the Minister to waive taxes, penalties, and arrears interest. ...
Article Summary
Doron Barkai, Alexander Demner, "Dealing with New Subsection 55(2): Issues and Strategies", 2016 Conference Report (Canadian Tax Foundation), 6:1–56 -- summary under Subsection 55(2)
. … [M]any tax practitioners are concerned that any dividend that would entitle the corporation to recover the part IV tax could be included in the series of transactions because the jurisprudence has generally ascribed a very broad interpretation to the phrase "series of transactions. ... PUC-streaming under s. 84(1)(c) (pp. 6:45-46) …CRA has not made any specific comments regarding the potential application of new section 55 to PUC-streaming transactions. … Fundamentally, since PUC is primarily a class concept this planning requires the use of separate share classes. ...
Article Summary
Kevyn Nightingale, John Sorensen, "Backdating of Dividends", Tax Topics (Wolters Kluwer), No. 2392, January 11, 2018, p. 1 -- summary under Paragraph 82(1)(a)
" [fn 11: … Wood …88 DTC 1180…] Need to codify CRA practice on finalizing salary/dividend mix (p. 3) We would recommend an express CRA policy permitting the crystallization of compensation and dividends in an owner-managed business to occur, for example, up to 60 days after fiscal year end (to match the due date for T5 slip filing). ...
Article Summary
Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50 -- summary under Derivative Forward Agreement
Exchangeable securities – exclusion for embedded exchange rights? (pp. 10:15-16) When dealing with exchangeable shares…the Department of Finance's view in the technical notes is that the taxpayer would retain sufficient economic exposure to the shares of the Canadian corporation such that the agreement to sell those shares would not be a DFA…. ... Currency forwards as potential DFAs (pp. 10:h18-19) [T]he calculation of the forward price under a currency forward agreement takes account of: (i) the spot exchange rate at the time the forward agreement is entered into, (ii) the interest rate in the base currency, (iii) the interest rate in the secondary currency and (iv) the term of the agreement. … [A] taxpayer may choose to sell forward USD$100 in a year to hedge its exposure to the US dollar. ... In any event, if the currency forward transaction would be a DFA under the analysis in paragraph (c), it is arguable that an exclusion under paragraph (b) would not be sufficient to conclude that the currency forward transaction would not be a DFA. … [G]iven that the common law principles as to whether currency transactions should be on capital account are well-established, and the fact that the intent of a currency forward transaction does not fit within the description of the type of transaction being targeted by the DFA Rules, presumably the underlying intent of the DFA Rules is not for all currency forward agreements to be DFAs…. ...
Article Summary
Randy S. Morphy, Kim Maguire, "An Update on the Taxation of Farm-outs", Resource Sector Taxation, Vol. IX, No. 3, 2013, p. 661. -- summary under Canadian Resource Property
Canadian Pipelines & Petroleum Limiter et al. [fn 11: (2959), 21 DLR (2d) 497 (S.C.C.) at 169-70, although we note that in the particular case, the Court found that the option was rendered void and of no effect because of a regulatory prohibition. ...
Article Summary
Doron Barkai, Alexander Demner, "Dealing with New Subsection 55(2): Issues and Strategies", 2016 Conference Report (Canadian Tax Foundation), 6:1–56 -- summary under Subsection 248(10)
. … [M]any tax practitioners are concerned that any dividend that would entitle the corporation to recover the part IV tax could be included in the series of transactions because the jurisprudence has generally ascribed a very broad interpretation to the phrase "series of transactions. ...
Article Summary
Pooja Samtani, "Requirements on the Rise: Defending Against Demands for Taxpayer Information", Tax Management International Journal, 2013, p. 357 -- summary under Subsection 231.2(1)
Canada Customs & Revenue Agency, 2004 FC 573 at ¶33, aff'd 2005 FCA 68.] ...
Article Summary
Austin del Rio, "Part VI.1 Tax on Dividend Paid Through Family Trust", Tax for the Owner-Manager, Vol. 19, No. 3, July 2019, p. 9 -- summary under Subsection 191.1(2)
X. … Mr. X owns voting preferred shares, allowing him to control Opco. ... X …. Thus, Holdco should have a substantial interest in Opco. Whether trust has a substantial interest (p. 10) [T]he CRA has confirmed that a trust will be related to a person if that person is related to all of the trustees of the trust (2009-0311891l70…and 2002-0117885 …). ... [A]ny corporate beneficiaries of the trust will be controlled by another beneficiary and should also be related (subparagraphs 251(2)(b)(i) and (iii)). … [A]ny trusts that are beneficiaries of the trust will likely be related when the trustees of such trusts are related to the other beneficiaries of the trust. … [U]nrelated trusts may still be beneficially interested in the trust, even before their creation….due to the broad meaning of “beneficially interested,” … [in s.] 248(25)…. ...