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Public Transaction Summary
Slate No. 2 -- summary under Foreign Asset Income Funds and LPs
Slate No. 2-- summary under Foreign Asset Income Funds and LPs Summary Under Tax Topics- Public Transactions- Offerings- REIT, Trust and LP Offerings- Foreign Asset Income Funds and LPs Slate U.S. Opportunity (No. 2) offering: initially unlisted Canadian mutual fund trust investing in US real estate through hybrid LPs Structure Slate Trust (an Ontario trust) will use the offering proceeds (of up to U.S.$50M) to invest in the units and interest-bearing notes (the "Investment LP Notes") of an Ontario LP ("Investment LP") which, in turn, will invest in the units of a Delaware LP ("Holdings LP"). ...
2 November 2023 APFF Roundtable
Roundtable notes
The change in position is applicable to debts settled or extinguished on or after November 2, 2023. ... Situation 2 A taxpayer has incurred operating losses since 2010 and has not claimed CCA for each of those years. ... Official Response 2 November 2023 APFF Roundtable Q. 15, 2023-0982901C6- Impact of the Collins Family Trust decision ...
2 December 2019 CTF Conference - Paul Wilson in "New Taxation Rules for Private Corporations: So far, so reasonable?"
Miscellaneous correspondence
Email this Content 2 December 2019 CTF Conference- Paul Wilson in "New Taxation Rules for Private Corporations: So far, so reasonable?" Guidance for Auditors Question Answer TOSI Examples Scenario 1- Corporate income derived from GIC Answer Scenario 2- Corporate income derived from 3rd-party managed investments Answer Scenario 3- Car rental business Answer Scenario 4- Insurance broker Answer Scenario 5- Hotel with no guest services Answer Scenario 6- Landscaping business sells sod Answer Tracing and Streaming Question Answer "Reasonable Return" Q.1- Evaluation in the field Answer Q.2- Instructions to auditors Answer This provides abbreviated summaries of comments made by Paul Wilson (Director, Medium Business Audit Division, Small and Medium Enterprises Directorate (the "Directorate")) at the 2 December 2019 Annual Conference of the Canadian Tax Foundation in Montreal in the presentation "New Taxation Rules for Private Corporations: So far, so reasonable? ... Scenario 2- Corporate income derived from 3rd-party managed investments A corporation that holds $5 million in portfolio investments is owned by 4 shareholders who are siblings. ...
2 December 2014 Annual CTF Roundtable
Roundtable notes
Written Response 2 December 2014 CTF Conference Q. 2, 2014-0546911C6 Q2. ... Written Response 2 December 2014 CTF Conference Q. 2, 2014-0546911C6 Q3. ...
FCTD (summary)
Northern and Central Gas Corp. Ltd. v. The Queen, 85 DTC 5144, [1985] 1 CTC 192 (FCTD), aff'd 87 DTC 5439, [1987] 2 CTC 241 (FCA) -- summary under Class 2
The Queen, 85 DTC 5144, [1985] 1 CTC 192 (FCTD), aff'd 87 DTC 5439, [1987] 2 CTC 241 (FCA)-- summary under Class 2 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 2 The subparagraphs of class 2 were intended to encompass the whole process of the production and distribution of electricity, heat, water and natural gas. ...
FCA (summary)
Nova, an Alberta Corporation v. The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA) -- summary under Class 2
The Queen, 88 DTC 6386, [1988] 2 CTC 167 (FCA)-- summary under Class 2 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 2 Pipes and valves located between the inlet and outlet connections of the main pipeline and to and from the compressor station and metering facilities were integral parts of the compressor stations and metering facilities rather than integral parts of the pipeline and therefore were not described in paragraph 1(b). ...
SCC (summary)
Johns-Manville Canada v. The Queen, 85 DTC 5373, [1985] 2 CTC 111, [1985] 2 S.C.R. 46 -- summary under Improvements v. Repairs or Running Expense
The Queen, 85 DTC 5373, [1985] 2 CTC 111, [1985] 2 S.C.R. 46-- summary under Improvements v. ... The land expenditures were currently deductible partly in light of (1) their recurring nature, (2) the absence of an enduring benefit because similar expenditures were required in the future if the mining operation was to be continued (and the lands were in a sense "consumed") and (3) the fact that they were not made as part of a plan for the assembly of ore bodies or other assets. ...
SCC (summary)
Mattabi Mines Ltd. v. Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175 -- summary under Interpretation Bulletins, etc.
Ontario (Minister of Revenue), [1988] 2 CTC 294, [1988] 2 S.C.R. 175-- summary under Interpretation Bulletins, etc. ...
SCC (summary)
Johns-Manville Canada v. The Queen, 85 DTC 5373, [1985] 2 CTC 111, [1985] 2 S.C.R. 46 -- summary under Class 31
The Queen, 85 DTC 5373, [1985] 2 CTC 111, [1985] 2 S.C.R. 46-- summary under Class 31 Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 31 Estey, J. stated, obiter, that if it were not for the addition of Class 26 to Schedule II, expenditures for catalysts would be currently deductible. ...