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Article Summary
Angelo Nikolakakis, "Guess Who's Back? The Revised Stub Period Rule for FAPI", International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 8 -- summary under Subsection 91(1.5)
. … [I]t is not clear why this measure is elective, since it is difficult to see a circumstance where this result would not be desirable from the perspective of the particular taxpayer,… [T]his measure may, to some extent, be helpful in non-arm's length situations involving transfers (or other acquisitions and dispositions) involving corporations and individuals or trusts. ...
Article Summary
Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report -- summary under Paragraph 1100(2.2)(f)
. … [L]eased equipment that is acquired with the intention of immediately selling it to the limited partnership may not be considered to be depreciable property. ...
Article Summary
Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure?", Canadian Tax Journal, (2016) 64:4, 833-58 -- summary under Paragraph 212(3.9)(b)
In order to rely on the exemption from withholding tax under the Canada-US treaty [fn 61: … at article XII(3)(b)] the Canadian requests a representation from the licensor that there is no licensing arrangement that may be caught by the connection test in the back-to-back rules. ...
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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 (2)-(41)
Putter … [F.n.168 2014 MBQB 254] appear to support the CRA's position. ...
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 118.1(6)
[F.n.259 – CRA document no. 2013-0486701E5, July 15, 2013.] For example, assume that a trust holds private company shares with a fair market value of $1 million and a $100,000 cost, and it wants to donate the shares to a private foundation. ...
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 104(24)
[F.n.283 – Cindy Radu and Siân Matthews, "Trust Administration—Best Practices," in 2010 Atlantic Provinces Tax Conference (Toronto: Canadian Tax Foundation, 2010), 4A:l-20. ...
Article Summary
Lorenzo Bonanno, Guy Buckley, "Limited Liability Partnerships", Canadian Tax Highlights, Vol. 25, No. 2, February 2017, p. 7 -- summary under Paragraph 40(3.14)(a)
. … Full-shield protection generally protects a partner against most partnership liabilities. ...
Article Summary
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 Paragraph 20(1)(r)
[fn 220: … 2007-025985117… 2010-0388761R3] Distributions to Canadian-resident employees from the RCA are taxed in the year in which they are received under paragraph 56(1)(x), and are subject to withholding tax under paragraph 212(1)(j),… ...