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Assume that the current spot rate for the Canadian dollar is US$1 = Cdn$1.25 and the taxpayer enters into an agreement to sell US$1 million a year from now at the forward rate of US$1 = Cdn$ 1.2685. If in a year's time the spot rate is US$1 = Cdn$1.20 (that is, the Canadian dollar has appreciated against the US dollar), the taxpayer realizes a gain of Cdn $68,500 (by selling US$1 million for Cdn$l,268,500 rather than at the spot rate of Cdn$1.20 or Cdn$1.2 million). ...

The notion that one can do so is closely related to the 18 th-century (and later Marxist) labour theory of value – an intuitive notion that has since been thoroughly debunked in the economic literature. ... Certain "Secondary income" – derived from income previously subject to attribution – will be subject to TOSI. ...

David Bunn, Mark Dumalski, "Proposed Amendments to Subsection 85.1(4)", International Tax Highlights, Vol. 1, No. 2 November 2022, p. 6-- summary under Subsection 85.1(4) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(4) Target of current s. 85.1(4) (p. 6) The current version of s. 85.1(4) avoids deferral of the capital gain that would otherwise be realized on the outright sale of a directly held FA (the first affiliate) through transferring it under s. 85.1(3) to a second affiliate, which then sells the first affiliate shares to a subsequent acquiror – where the first affiliate shares are excluded property so that such sale occurs on a deferred basis. ... Providing a carve-out for subsequent FA acquirors only where they are controlled by the taxpayer and other non-arm’s-length Canadian residents represents an abandonment of a “votes and value” test in favour of a test of voting control – which could open up opportunities to transfer the economics associated with the ownership of an FA (but not its de jure control) out from under Canada. ... That said, all or substantially all of the property of the first affiliate might be excluded property at the time of the initial transfer, but the first affiliate shares, or any other shares deriving their value from such shares, could not be excluded property at the time of the subsequent disposition – in which event, the initial transfer would be denied rollover treatment even though the subsequent disposition triggered FAPI. ...

Joint Committee, "Submission regarding proposed audit powers in Budget 2024 included in the August 2024 Draft Legislation", 11 September 2024 Joint Committee Submission-- summary under Subsection 231.9(6) Summary Under Tax Topics- Income Tax Act- Section 231.9- Subsection 231.9(6) Inappropriate scope of s. 231.9 rule (pp. 7-10) Where the taxpayer refuses to provide information on the basis of solicitor-client privilege and the Minister nonetheless issues a notice of non-compliance (NNC), this could pressure the taxpayer into waiving privilege rather than undertaking the onerous NNC dispute process – suggesting that since a compelled waiver is not valid, the production of documents resulting from the NNC’s issuance would likely constitute an unreasonable search or seizure contrary to s. 8 of the Charter. ... This requirement for a review of correctness clashes with s. 231.9(9), which contemplates the Federal Court reviewing whether any CRA decision to reject a privilege claim in relation to a document covered by a NNC was reasonable, a review which generally would be limited to considering that decision in light of the material before the CRA decision maker – which, crucially, would not include the document for which privilege was claimed. In contrast, the Federal Court’s review under s. 231.7 of any compliance order sought by the Minister of a document for which the taxpayer claimed privilege would be applied under a correctness standard (likely including a review of the document) – so that there could be a situation (representing an affront to the rule of law) in which taxpayer was penalized under s. 231.9 for what was subsequently established not to be a failure. ...

A himself, so this condition cannot be met; paragraph 56.4(6)(d) requires the covenant be an undertaking not to compete with the purchaser in the acquisition or with a person related to the purchaser – here, Mr. ... C do not form a related group), so this condition cannot be met either; … Unavailability of s. 56.4(7) safe harbour (p. 1607) Subsection 56.4(7) provides another exception to the section 68 deemed reallocation rule. ... C looks to subsection 56.4(4) – which at first glance appears to align the tax treatment of the restrictive covenant payment between payer and payee. ...

Convention in its application to a U.S. citizen or resident who has a TFSA, they state (at pp. 2-3): The sole remaining question is whether a TFSA is operated "exclusively to provide pension … benefits". ... Retirement is one of the listed objectives – generally a major objective. ...

(p. 6) The proposal's charging provision operates whenever – vis-à-vis a particular CFA – there is a decrease in a taxpayer's surplus entitlement percentage (SEP), calculated as if the taxpayer were a Canco. ...

[fn 50: … 2003-0019751E5 ….] Arguably, this analysis could also be applied where foreign tax is imposed in contravention of a treaty under a domestic anti-treaty shopping rule. ...

See also CRA Document No. 9831647, Lawyer's trust account, February 19, 1999, and CRA Document No. 2007-0233761C6, 2007 Step Conference – Question 1 – In-trust accounts. ...

[See now draft amendment to s 89(1) – CDA – (c.2)(i).] ...