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Decision summary
Williams Moving & Storage (B.C.) Ltd. v. Canada (Minister of National Revenue), 2024 BCCA 160 -- summary under Rectification & Rescission
Williams Moving & Storage (B.C.) Ltd. v. Canada (Minister of National Revenue), 2024 BCCA 160-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission bankruptcy proposal which CRA had misinterpreted is corrected pursuant to discretion under the BIA A drafting error (involving an inappropriate duplication of text) in the proposal which was approved by the creditors of an insolvent company (Williams Moving) and by the B.C. ... In finding that the chambers judge had not erred in denying rectification of the written terms of the proposal, Wilcock JA noted (at para. 68) the finding in Fairmont that “rectification requires the parties to show an antecedent agreement with respect to the term or terms for which rectification is sought” and stated (at paras. 69): [I]t is difficult to see how it can be said that the creditors would have understood the Proposal to be anything other than what was presented to them. … There was insufficient evidence of a common understanding amongst the appellant and its creditors on the matter in dispute …. ...
Article Summary
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)
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). ...
Article Summary
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)
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. ...
Article Summary
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)
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. ...
Article Summary
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission -- summary under Variable B
Joint Committee, "Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction", 26 March 2024 Joint Committee Submission-- summary under Variable B Summary Under Tax Topics- Income Tax Act- Section 183.3- Subsection 183.3(2)- Variable B Acquisition of Targetco for cash and Acquisitionco equity Where the shareholders of Targetco (which will not be delisted until some time thereafter) are to receive a combination of cash and shares of Acquisitionco, the cash component is included in Variable B of the formula in proposed s. 183.3(2) (so that it is subject to the tax) because equity of a covered entity (Targetco) is acquired in the taxation year pursuant to a reorganization transaction described in para. ...
10 October 2024 APFF Financial Strategies & Instruments Roundtable
Miscellaneous correspondence
"[FN: Notes by David SHERMAN, Practitioner’s Income Tax Act, 50th [French] edition, Thomson Reuters, 2024, s. 12(13) I.T.A.] ... In June 2024, he decides to rent out his residence and does not make the election under subsection 45(2). ... More specifically, the reduction is equal to the amount by which the CCPC's deduction for the year under subsection 126(1) (the “FTD”) in respect of its foreign non-business income (clause (A) of element B of the “A – B” formula) exceeds 8% of the foreign investment income ("FII") (clause (B) of element B of the “A – B” formula). ...
Article Summary
Joint Committee, "Subject: Federal Budget 2024 – Capital Gains Inclusion Rate", 1 May 2024 Joint Committee Submission -- summary under Paragraph 38(a)
Joint Committee, "Subject: Federal Budget 2024 – Capital Gains Inclusion Rate", 1 May 2024 Joint Committee Submission-- summary under Paragraph 38(a) Summary Under Tax Topics- Income Tax Act- Section 38- Paragraph 38(a) design issues for proposed shift to the 2/3 capital gains inclusion rate Comments of the Joint Committee on the design issues for implementing the increase in the capital gains inclusion fraction to 2/3 included: In order to avoid costs, difficulties, uncertainties, or impediments in actually realizing capital gains before June 25, 2024, taxpayers should be permitted to file an election (see s. 110.6(19)) to be deemed to have realized all or a portion of their accrued capital gains before that date. ... With a view to avoiding retroactive effects of the increased inclusion fraction: Capital gains reserves from pre-June 25, 2024 dispositions should be brought into income at the ½ rate; The ½ deduction should be maintained for distributions from hybrid surplus generated from pre-June 25, 2024 dispositions (which might entail drafting for a second category of hybrid surplus). Amendments to s. 110(1)(d.1) should include a continuation of the 50% deduction rate for CCPC options exercised prior to June 25, 2024; Capital gains realized by a trust or partnership prior to June 25, 2024 should maintain that time stamp when allocated to beneficiaries or members (which could entail changes to the capital gains refund mechanism). ...
Current CRA website
T2 Corporation – Income Tax Guide – 2024
T2 Corporation – Income Tax Guide – 2024 From: Canada Revenue Agency T4012(E) Rev. 24 The CRA's publications and personalized correspondence are available in braille, large print, etext, and MP3. ... La version française de ce guide est intitulée Guide T2 – Déclaration de revenus des sociétés. ... Table of contents Footnote 1 What's new Before you start Chapter 1 – Page 1 of the T2 return Identification Chapter 2 – Page 2 of the T2 return Attachments Information schedules and forms Calculation schedules Chapter 3 – Page 3 of the T2 return Attachments Additional information Calculating net income or loss Losses How to complete Schedule 4, Corporation Loss Continuity and Application Taxable income Chapter 4 – Page 4 of the T2 return Small business deduction Chapter 5 – Page 5 of the T2 return General tax reduction Chapter 6 – Pages 6 and 7 of the T2 return Refundable portion of Part I tax Refundable dividend tax on hand Dividend refund Chapter 7 – Page 8 of the T2 return Part I tax Chapter 8 – Page 9 of the T2 return Summary of tax and credits Federal tax Provincial and territorial tax Other credits Refund or payment Payment of balance owing Direct deposit request Mandatory electronic filing for tax preparers Certification Language of correspondence Related forms and publications List of federal and provincial or territorial corporation schedules and forms Digital services Handling business taxes online Electronic payments For more information If you need help Direct deposit Forms and publications Electronic mailing lists Teletypewriter (TTY) and Video Relay Service (Canada VRS) users Formal disputes (objections and appeals) Service complaints Reprisal complaints Due dates Non-resident corporation enquiries Index Footnotes Footnote 1 For more detailed content listings, see the first page of each chapter. ...
Article Summary
EY, "Concessional loans – Claimants may amend prior SR&ED claims for taxation years that are not statute-barred", Tax Alert 2024 No. 54, 15 November 2024 -- summary under Government Assistance
EY, "Concessional loans – Claimants may amend prior SR&ED claims for taxation years that are not statute-barred", Tax Alert 2024 No. 54, 15 November 2024-- summary under Government Assistance Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Government Assistance prior SR&ED claims for non-statute-barred years can be amended to reflect excluded loans CRA representatives confirmed that taxpayers impacted by the change in the definition of government assistance to carve out excluded loans may submit amended tax returns with their revised SR&ED forms for the years affected even where their SR&ED reporting deadline has passed, provided that the taxation year is not statute-barred. ...
Current CRA website
Businesses – Tax information newsletter, Edition: 2024-05 – October 23, 2024
Businesses – Tax information newsletter, Edition: 2024-05 – October 23, 2024 It's Small Business Week 2024 – explore the CRA's tools to support Canada's entrepreneurs This Small Business Week, the Canada Revenue Agency (CRA) is celebrating the dedication and impact of small business owners— the heart of our communities. ... Most businesses should receive their payment by: December 16, 2024, if registered for direct deposit; or, December 31, 2024, if receiving a payment by cheque. ... The first filing deadline is January 31, 2025 for the 2024 calendar year. ...