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Article Summary
Carla Hanneman, "Reorganization Strategies for Proposed Paragraph 55(3)(a)", Canadian Tax Focus, Volume 5, Number 3, August 2015, p.8. -- summary under Paragraph 55(3)(a)
Alternative using butterfly-style mechanics (p. 9) Some practitioners might consider another way of implementing the transfer, which differs in steps 3 through 6: … 3) Holdco transfers shares of Opco (with a value equal to the value of the OPco assets transferred to Newco in step 2) to Newco in exchange for shares of Newco on a tax-deferred basis. 4) Newco redeems the shares that it issued to Opco in step 2 and issues a note to Opco as an in-kind redemption payment for the redeemed shares. 5) Opco redeems the shares that Newco received in step 3, and issues a note to Newco as an in-kind redemption payment for the redeemed shares. 6) The notes issued in steps 3 and 4 are offset and cancelled. ...
Article Summary
Angelo Nikolakakis, Alain Léonard, "The Acquisition of Canadian Corporations by Non-Residents: Canadian Income Tax Considerations Affecting Acquisition Strategies and Structure, Financing Issues, and Repatriation of Profits", 2005 Conference Report, c. 21, p. 21:8. -- summary under Subsection 212.1(4)
Section 212.1 does not apply because this is not a transfer of the shares of one corporation resident in Canada to another, and there is no gain from the disposition of the Target shares because they were just acquired in a taxable arm's-length transaction. 30 In step 2, Bidder transfers Bidder Forco shares and the Bidder Forco reorganization note to Bidder Canco in | exchange for Bidder Canco shares and a promissory note ("the Bidder Canco capital note") in an appropriate combination. ...
Article Summary
Joyce A. Young, H. Michael Dolson, "Income Tax Consequences of Carrying on an Unrelated Business", Business Vehicles, Volume XV, No. 1, 2012, p. 782, at 783, 784-785 -- summary under Subsection 188.1(1)
.] … There appears to be some consensus between the Minister and the academic commentators that the carrying on of a business by a trust established for the benefit of a charity does not constitute a business of the charity.… The better view of the law is that the business carried on by a trust is a business of the trustees and not a business of the trust beneficiaries. ...
Article Summary
Marie-Eve Gosselin, Paul Lynch, "A Review of Interest Deductibility Since Ludco", 2015 CTF Annual Conference paper -- summary under Paragraph 20(1)(c)
. … CRA challenges to intercompany interest charges (p.7:18) We have seen challenges [to the reasonableness of the interest rate] in related groups, between sister companies, parents and subsidiaries, and cross border hybrid debt structures. ...
Article Summary
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper -- summary under Subsection 80(13)
. … [C]areful tax modeling will be required to ensure that no material cash taxes will arise in the year of the restructuring as a result of the income inclusion under subsection 80(13), taking into account the potential five-year inclusion under section 61.4…. ...
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 Subsection 212(3.2)
The deemed interest will be $20, because it is adjusted to reflect the difference in withholding tax rates between payments to NR 1 and NR 3, as a proportion of the rate on payments to NR 1 (that is, [15% — 10%]/15%). ...
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 Paragraph 251.1(4)(d)
[fn 54: 2009-0308611R3 ….] This interpretation may not be correct as a matter of trust law. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Beneficiaries Resident in Canada", Chapter 4 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016. -- summary under Subsection 107(1)
[fn 20: … 2004-0061841E5] Potential for double taxation (p. 270) The sale or other disposition of a capital interest in a trust could give rise-to double taxation to the purchaser of the interest when the trust disposes of its property to a third party following the acquisition of the trust interest by the purchaser. ...
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 70(6)(b)
However, in a technical interpretation in 2003 [fn 121:… 2003-0008285 …] the CRA responded ambiguously in respect of a testamentary spousal trust that allocated the spouse all of the income that arose before her death, provided that she could force a distribution of income only every three years, with a "catch up" in the year of death…. ...
Article Summary
Manal Corwin, Jesse Eggert, "Understanding the Operation, Impact, and Practical Implications of the MLI", Tax Management International Journal, Vol. 46, No. 8, 11 August 2017, p. 407 -- summary under Article 13
.] … Principal purpose test can be applied to avoidance of permanent establishment even if only one Treaty (“CTA”) adopts MLI Art. 13 (pp. 414-5) [E]ven where only one party to a CTA adopts provisions expanding the PE article, it may have effect under the domestic law of a source country if that country invokes the PPT to deny treaty protection. ...