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. … The specified factor of 0.35 operates as a form of rough justice, but does not distinguish between different rates of tax…. ...

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MNR, [fn 6: 70 DTC 1208 …]… [R]oland St-Onge QC compared the legal status of a GmbH under German law with the legal status of a corporation under Canadian law. ...

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022-- summary under A Summary Under Tax Topics- Income Tax Act- Section 18.2- Subsection 18.2(1)- Adjusted Taxable Income- A Double-deductions of non-capital losses Item A in the ATI formula is reduced by the non-capital loss and net capital loss generated for the current year – yet if these losses are applied in a future year, there is no consequential ATI adjustment for that subsequent year (except for the partial addback of the portion of a non-capital loss that reasonably relates to the taxpayer’s net interest and financing expense). ...

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022-- summary under Acceptable Accounting Standards Summary Under Tax Topics- Income Tax Act- Section 18.21- Subsection 18.21(1)- Acceptable Accounting Standards Non-recognition of local European GAAP The group ratio rule in draft s. 18.21, which may enable taxpayers to access a higher fixed percentage than 30% where the group as a whole is bearing higher interest and financing expenses as a result of its external debt and as measured by the group GAAP financial statements, does not recognize any local European GAAP – so that the group ratio calculations could be unavailable for European-headed groups that do not consolidate using IFRS. ...

Joint Committee, "Reportable Transaction and Notifiable Transaction Proposals", 5 April 2022 Joint Committee Submission-- summary under Avoidance Transaction Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(1)- Avoidance Transaction Expansion of “avoidance transaction” (pp. 8-10) The change of the “avoidance transaction” test to refer to “one of the main purposes” of the transaction or series (rather than using a “primarily” test for a transaction) means that, for example, having a small safe income dividend (representing an acceptable tax benefit) as part of a series would render all transactions in the series avoidance transactions – so that the presence of only one hallmark would engage a reporting requirement. ...

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022-- summary under Clause 95(2)(f.11)(ii)(D) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(f.11)- Subparagraph 95(2)(f.11)(ii)- Clause 95(2)(f.11)(ii)(D) No carryforward (pp. 4-5) Per s. 95(2)(f.11)(ii)(D), where a portion of a taxpayer’s IFE for a taxation year is denied under s. 18.2(2), the same proportion of a CFA’s relevant affiliate IFE is similarly denied for purposes of computing its FAPI for the relevant taxation year – but, unlike the treatment of restricted IFE (which may be carried forward to a subsequent year depending on the availability of excess capacity), the denied deduction for purposes of computing FAPI of a foreign affiliate apparently cannot be carried forward. ...

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022-- summary under Subsection 18.2(4) Summary Under Tax Topics- Income Tax Act- Section 18.2- Subsection 18.2(4) Transferee can have a different functional currency or be a REIT (p. 7) The EIFEL revisions have removed the requirement that cumulative unused excess capacity could only be transferred between eligible group corporations that have the same functional currency – and transfers of capacity respecting a “fixed interest commercial trusts” (e.g., most REITS) can now be made. ...

Mark Brender, Marc Roy, "Canadian Tax Trap Arising from Cross-Border Gift Tax Planning", Tax Notes International, Vol. 111, 4 September 2023, p. 1217-- summary under Paragraph 94(2)(k) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(2)- Paragraph 94(2)(k) Example of application of s. 94(2)(k) (p. 1219) S. 94(2)(k) could, for example, apply if a Canadian resident asks or directs a nonresident to settle a nonresident trust or otherwise transfer or lend property to the trust, with a view to avoiding the trust being deemed resident in Canada – so that there would be a deemed joint contribution, and a resulting deemed contribution by the Canadian resident. ...

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 Section 231.41 Summary Under Tax Topics- Income Tax Act- Section 231.41 Procedural protections under the parallel IRC rule (pp. 5-6) Although the IRS has the power to summon various persons including taxpayers, officers, employees or third parties to provide testimony under oath (26 USC §7602(a)(2)), in contrast to s. 231.45 there are also various procedural protections to protect witnesses rights including the right to request that proceedings be recorded and the right to be represented by counsel – and a summons may not be issued while a matter is under criminal investigation. ...