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Article Summary
Paul Barnicke, Melanie Huynh, "FA's LP Interest: Excluded Property?", (2015) vol. 23, no. 4 Canadian Tax Highlights, 4-5 -- summary under Excluded Property
This result follows because the postamble in the "excluded property " definition refers to an interest in a partnership that is owned by an FA of a taxpayer, and that taxpayer can be any taxpayer (Canco 4, in this case) and not only the taxpayer (Canco 3) referred to in the preamble. ...
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Didier Fréchette, Ryan Rabinovitch, "Current Issues Involving Foreign Exchange", 2015 CTF Annual Conference paper -- summary under Subsection 93(2.01)
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Sze Yee Ling, Nathan Wright, "Restrictive Covenants: Some Reminders", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 7 -- summary under Restrictive Covenant
. … [M]any provisions found in a typical shareholders' agreement (such as a clause requiring that the parties not carry on any other businesses) could trigger the application of the restrictive covenant regime upon a sale of shares, because any sale would be subject to the terms of the agreement. ...
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Clara Pham, "Paying FA Dividends When Surplus Balances are Unclear", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 2 -- summary under Paragraph 5901(2)(b)
. … Any dividend on which an election is not made will first come out of exempt surplus…. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under Subsection 105(1)
. … [CRA’s] administrative position is that a parent has not received a benefit when the trustees pays for the necessities of a minor beneficiary in accordance with the terms of the trust. ...
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Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Classification of Trusts for Income Tax Purposes", Chapter 2 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016. -- summary under Subsection 104(1)
[fn 107: … Brookview Investments Ltd… v. MNR, 63 DTC 1205 (Ex. Ct.): and De Mond v. ...
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Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under Excluded Obligation
. … All subscription agreements will generally have a covenant that the PBC will indemnify FTS holders if the tax deductions promised are not delivered.... ...
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 Paragraph 84(1)(c)
. … Fundamentally, since PUC is primarily a class concept this planning requires the use of separate share classes. ...
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Joint Committee, "Legislative Proposals to Address Income Sprinkling Released December 13, 2017", 8 March 2018 Joint Committee Submission -- summary under Arm's Length Capital
. … If an individual borrows from an arm’s length party (e.g. a financial institution) without any security or guarantee provided by a source individual, that borrowing should conceptually be arm’s length. ...
Article Summary
Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper -- summary under Paragraph 7(1)(b)
CRA’s position is that the present value of the contingent payment must be included in income up front ….] ...