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10 June 2011 Roundtable, 2011-0404621C6 F- Rectification order in Québec-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission CRA awaiting resolution of AES and Riopel cases CRA noted that as the ARQ had sought leave to appeal the AES decision to the Supreme Court and the period for seeking leave in Riopel had not yet expired, it would prefer to refrain from commenting on those decisions effect on CRA’s views on rectification. ...

25 March 2009 External T.I. 2008-0300401E5 F- Fiducie en faveur de soi-même- prêt sans intérêt-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt individual pays trust taxes when he receives trust distributions net of such taxes CRA indicated that an individual would be considered to be personally paying taxes of a trust that had made a s. 104(13.1) where he received distributions from the trust net of such taxes. ...

6 July 1994 Administrative Letter 9323826 F- Bonds Issued in Lieu of Interest-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt issuance of bonds re accrued interest did not constitute payment thereof Bonds issued to a Canadian bank in settlement of arrears interest on a non-performing loan of a Brazilian debtor would not be considered to constitute payment by the debtor and receipt by the bank of interest on the underlying loans, in light of the comments in Cross v. ...

5 January 1996 CTF Roundtable Q. 31, 9523976- GROSS-UP PAYMENTS-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A gross-up on a debt obligation owing to a Canadian lender will be included in the Canadian lender's income under s. 9 or s. 12(1)(c) even "where the gross-up is paid or credited to the government of a foreign country on the Canadian lender's behalf since the Canadian lender would have constructively received the gross-up". ...

29 April 2003 External T.I. 2002-0177065 F- CONFISCATION DE LA SOLDE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt forfeited salary nonetheless includible as salary received CCRA indicated that salary that was forfeited by RCMP officer for misconduct nonetheless was to be treated as includible in the officer’s income as salary which was to be treated as having been received by the individual before its forfeiture as a fine. ...

25 June 2002 Internal T.I. 2002-0130177 F- DEBENTURE CONVERTIBLE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Teleglobe applied to find that amount paid by corporation on conversion of convertible debentures was the shares’ stated capital CCRA reviewed the line of cases culminating in Teleglobe, and concluded that the amount paid by the issuer on the conversion of its convertible debentures should be treated as the stated capital of the shares issued, which equaled the face amount of the converted debentures. ...

2021 Ruling 2021-0911211R3- Foreign Takeover-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt borrowing and payment of funds pursuant to an internal payment direction agreement CRA ruled on transactions which included the borrowing of money by a newly-formed non-resident corporation (Merger Sub1) from a Canadian affiliate (Opco) and its advance of such funds to a transfer agent for shareholders of a non-resident target (Target), pursuant to directions in an internal funding agreement. ...

10 October 2014 APFF Roundtable Q. 15, 2014-0538151C6 F- 2014 APFF Roundtable, Q. 15- Section 143.4 & Reverse Earn-out-- summary under Subsection 143.4(2) Summary Under Tax Topics- Income Tax Act- Section 143.4- Subsection 143.4(2) reverse earnout obligation of Buyco re Target shares A newly formed corporation ("Newco") purchases the shares of a target corporation ("Target") for consideration that includes an earn-out clause (resulting in a debt which is subsequently forgiven). ... However we can offer the following general comments which nonetheless, in some circumstances, would not apply in a particular situation. … … (a) …[A] reduction in the cost of the shares in the capital stock of Target through the application of subsection 143.4(2) prior to the amalgamation would in general permit the debt to qualify as "excluded obligation" as defined in subsection 80(1), by reason of the application of paragraph (a) of that definition. ...

LLPs & LLLPs-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 LLPs and LLLPs treated as corporations In concluding that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) governed by the laws of Florida and Delaware were corporations, CRA referred to their “separate legal personality” and “the extensive limitation of liability afforded to all of their members,” and also stated: [I]t has become widely accepted that U.S….LLCs…are properly viewed as corporations for the purposes of the Act, notwithstanding… Anson …. We see little substantive difference between LLPs, LLLPs and LLCs governed by the laws of the states of Florida and Delaware. … We suspect that much of this reasoning may be applicable in respect of entities of other states of the U.S. and perhaps other foreign jurisdictions…. ...

11 October 2017 External T.I. 2016-0660421E5- Foreign tax credit – former resident-- summary under Subparagraph 152(4)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(b)- Subparagraph 152(4)(b)(i) waivers generally cannot be used to extend the 6-year period for claiming a FTC under s. 126(2.21) The taxpayer, who had been resident in Canada for over five years, realized a capital gain from the deemed disposition of real property situated outside Canada under s. 128.1(4)(b) on emigrating from Canada. ... After noting that “an assessment to take into account a foreign tax credit under subsection 126(2.21) … in respect of foreign taxes paid is permitted only where the assessment is made within 3 years after the normal reassessment period,” CRA stated: [A] blanket waiver request without sufficient details of a transaction would likely not be considered valid. …[I]f any of the circumstances to support the deduction under subsection 126(2.21) of the Act (e.g., disposition of the property and/or foreign taxes paid) are present within the statutory assessment period referred to in paragraph 152(4)(b) …, it may be appropriate for the Minister to consider a taxpayer’s waiver request for the emigration year to allow the Minister sufficient time to review and process any potential reassessment for this deduction beyond the aforementioned reassessment period. ...