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Summary of 3 December 2024 CTF Roundtable, Q.14 under s. 129(4) – “income” or “loss”. ...

These are additions to our set of 3,053 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ...

Langlois, which found that a 50% shareholder who had “an operational role, not a decision-making role” was not part of the de facto control of the corporation, whereas the other shareholder, who “[a]s the sole director … had the power that ensured him a dominant influence in the direction of the [corporation]” had de facto control. ...

Summary of Joint Committee, Federal Budget 2024 – Capital Gains Inclusion Rate, 22 January 2025 Joint Committee submission under s. 38(a). ...

In finding that s. 152(4)(b)(vii) did not authorize CRA to reassess the trust within three years of the expiry of the normal reassessment period to adjust the proceeds of disposition, the Directorate indicated: The relevant scoping condition in s. 152(4)(b)(vii) – that the assessment was “to give effect to the application of section 94”- meant “to cause section 94 to apply.” ...

These are additions to our set of 3,123 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ¼ years of releases of such items by the Directorate. ...

There is not considered to be such a right where the shareholders’ agreement for a corporation carrying on a franchised operation (“Franchisee”) specifies that in the event that the individual manager of Franchisee (who holds 50% of Franchisee’s commons shares) departs, the other 50% common shareholder (the Franchisor) has the mandate to find a third party to purchase the manager’s shares – or that, in such event, the manager’s shares are to be automatically redeemed by Franchisee. ...

Summaries of Joint Committee, Submission letter entitled “Technical Amendments Package of September 16, 2016" dated 15 November 2016 under s. 87(8.4), s. 90(6.1), s. 91(4.6)(b), s. 91(1.2), s. 91(1.1). s. 91(1.5), s. 212.3(2), s. 212.3(7). s. 212.3(18), s. 212.3(9)(b), s. 219.1(3)(c). s. 248(1) – derivative forward agreement, Reg. 6204(1)(b). ...

The Queen, 2017 TCC 13 under General Concepts – Agency, ETA s. 153(1), s. 232(3). ...

Treaty, that Article requires that the transfer to the spousal trust be made under a will – which is often a problem because US individuals often use an inter vivos trust to reduce or defer US estate tax. ...