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– Part II", Tax Topics, Wolters Kluwer, No. 2274, October 8, 2015, p.1.-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Test is one simply of true intention, not specific intent (pp. 3-4) In Juliar,…[t]he key passages from the Court of Appeal are these:… [I]t is possible,, even probable, that no one mentioned income tax throughout the nine or 10 months in issue. ... If there is no requirement for due diligence, it means that rectification is available even when there is a mistake — even a negligent mistake [f.n. 10. ... Coutts & Co, [2006] EWHC 1502 (Ch.) at paragraph 11, the Courts granted rectification even though the mistake was caused clearly by a professional advisor's negligence. ...

PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020-- summary under Investment Limited Partnership Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Investment Limited Partnership Meaning of “principal activity” A person’s “principal activity,” as discussed … in College of Applied Arts … depends on how important a particular activity assists the person in achieving its overall business objectives and goals when compared to its other business activities. ...

Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(1)- Reorganization- Paragraph (b) Vertical amalgamations It is common for an “Acquisitionco” to acquire all the shares of a public company target (“Targetco”), whose shares are not delisted until after a delay, and to vertically amalgamate with it. ... (b) of the definition, the equity holders of the covered entity (Acquisitionco as the holder of Targetco shares) must receive equity of Amalco – and such equity is instead cancelled for no consideration. ...

Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Subsection 183.3(2) Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(2) Potential duplication under s. 183.3(2) Under a literal reading of s. 183.3(2), every covered entity would have an amount under Variable B when equity of any other covered entity is redeemed, acquired or cancelled pursuant to a reorganization transaction (and a portion of the consideration is not equity). ...

Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Distinction between employee and partner/fixed distribution entitlement (5-20) [I]gnoring for the present section 2(3)(b) [the same as Partnerships Act (Ont.), s.3.3(b)], it was frequently held prior to the 1890 Act that employees who were remunerated by reference to the profits of a business were not partners therein, at least where it appeared from the agreement that no partnership was intended. ... & C. 867; Ex p. Chuck (1832) 8 Bing. 469; Gilpin v. Enderby (1824) 5 B. & A. 954. In such a case, an express term in the agreement negativing any implication of partnership may be ineffective vis-a-vis third parties, such as HMRC: see Fenston v. ...

Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at p. 4:-- summary under Subsection 56.4(6) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(6) Paragraphs 56.4(6)(e) (arm's length employee exception) and 56.4(7)(d) ("goodwill amount" and "disposition of property" exceptions) provide that no proceeds can be received or receivable by the individual granting the RC. ...

Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part I", CCH Tax Topics, No. 2132, 17 January 2013, p. 1 at p. 3-- summary under Eligible Interest Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(1)- Eligible Interest It is uncertain why the above definition [of eligible interest] excludes shares of a corporation where, for example, that corporation owns all of the shares in the capital stock of two or more subsidiary corporations. ...

Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at pp. 3-4:-- summary under Subsection 56.4(12) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(12) Discussions with the Department of Finance indicate that the intent of paragraph 56.4(12)(b) is to prevent a taxpayer from arguing that an amount received or receivable by that taxpayer that reasonably relates to an RC granted by another taxpayer should not be included in that taxpayer's income because paragraph 68(c) prevents the Minister from allocating any portion of the RC to them. ...

Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(1)- Reorganization- Paragraph (c) Wind-Up of Targetco into Acquisitionco A public company target (“Targetco”), whose shares are not delisted until after a delay, is acquired by “Acquisitionco” and then wound-up into it. ...