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Large corp,/ transfer-pricing exclusion (pp. 8-10) Furthermore, errors by large corporations typically are attributable to the number and complexity of the tax-reporting issues faced by them, so that their exclusion would violate fundamental principles of fairness – as does blanket denial of relief to taxpayers respecting transfer pricing errors. ...

. … …[Scenario #3] The FTS holder disposes of its FTS to purchaser 1, who then sells to purchaser 2. ...

Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39-- summary under Paragraph 6202.1(1.1)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 6202.1- Subsection 6202.1(1.1)- Paragraph 6202.1(1.1)(c) Prescribed share issues if flow-through subscription receipts (p. 12:21-22) [I]f the subscription agreement for subscription receipts were structured as FTS, a prescribed-right issue would immediately be triggered – namely, it would be possible that the holder could get the subscription price back for the subscription receipt if the escrow conditions were not met. ...

[f.n. 126: … art, 28(2)(a).] Such "free form" reservations are subject to objection by other parties, and if a party objects, Part VI will not apply at all between the reserving party and the objecting party. ...

. … In TI 9608465, the CRA concluded that in a proposed merger of two trusts (the one trust being the “top fund” and the other being the “bottom fund” of a fund-of-fund structure), the top fund could not transfer units of the bottom fund to that fund: the proposed merger was not a qualifying exchange. ...

However, unlike paragraph 55(5)(f) …, subsection 55(2.3) does not explicitly split the dividend into two separate dividends. ...

Gabco test (p. 1) In Gabco … [t]he court established a frequently quoted (most notably, in Transalta Corporation v. ...

IV of the T1134 form contemplates that unavailable information will not be provided until later, CRA may now receive far more incomplete returns, and refiling returns will be inefficient both for taxpayers and CRA If there is an accelerated filing deadline, 12 months would be more appropriate so as to align with the filing deadline for country-by-country reporting – but even this would be problematic for jurisdictions such as the U.K. and Germany where tax returns are allowed to be filed 12 months after year end. ...

(a) of the definition of public corporation – that a listed Canadian corporation is a public corporation- be amended by adding a proviso that this will not be the case where the corporation ceased to be a public corporation under para. ...

In practice … we have found that CRA Appeals takes the position that the Appeals Branch has no authority to review a denied downward adjustment, and considers a notice of objection in which a denied downward adjustment is the only issue in dispute to be invalid. ...