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Michael Colborne, Michael McLaren, "Section 93 Elections — Proposed Amendments", Canadian Tax Journal, Vol. 58, 2010, p.357.-- summary under Subsection 5908(9) Summary Under Tax Topics- Income Tax Regulations- Regulation 5908- Subsection 5908(9) Preserves surplus adjustments for multi-tier partnerships (p. 378). ...

Turner, "Transitional Tax Treatment of Grandfathered Upstream Loans – Repayment Deadline Approaching", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 7-- summary under Paragraph 90(8)(a) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(8)- Paragraph 90(8)(a) August 19, 2016 repayment deadline for pre-August 20, 2011 loans (p.7) The paragraph 90(8)(a) carve-out from the upstream loan rules provides taxpayers with an effective and clear strategy to deal with grandfathered upstream loans. ...

Turner, "Transitional Tax Treatment of Grandfathered Upstream Loans – Repayment Deadline Approaching", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 7-- summary under Subsection 39(2.1) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2.1) Purpose of eliminating FAPI whipsaw mismatch (e.g., where US dollar upstream loan) due to sub’s taxable capital gain or allowable capital loss not being off-settable against parent’s loss or gain (pp. 7-8) [S]ubsection 39(2.1) and paragraph 95(2)(g.04)…appropriately recognize that taxpayers may have made historic upstream loans in a foreign currency, exposing themselves to the risk of the FAPI whipsaw mismatch but with the original intention of leaving the upstream loans outstanding indefinitely so as to defer any adverse consequences. ...

Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50-- summary under Paragraph 306(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 306- Subsection 306(1)- Paragraph 306(1)(b) Shift to one-year pre-test (p. 719) [T]he rule now requires only a one-year pre-test. ...

Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper-- summary under Subsection 39(2.02) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2.02) Background to s. 39(2.01) (pp. 13-14 Many Canadian companies have or had significant accrued foreign currency gains in their US dollar denominated debts, particularly where the debts were originally issued in 2001 or 2002…. ...

PWC, "GST/HST and QST alert: Investment plans are required to obtain investor percentages – action required by October 15, 2019", PwC Tax Insights, September 03, 2019, Issue 2019-31-- summary under Qualifying Investor Summary Under Tax Topics- Excise Tax Act- Regulations- Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations- Section 52- Subsection 52(1)- Qualifying Investor overview Qualifying investors A qualifying investor is generally an investor that is an investment plan (but not a DIP) that holds less than $10,000,000 in units in the DIP (or, if the plan is a stratified investment plan, holds less than $10,000,000 in units in a series of the plan) and is: a person that is not a qualifying small investment plan (QSIP) or a pension plan whose members reside almost exclusively in non-HST provinces for GST/HST purposes (or exclusively outside Quebec for QST purposes) or a private investment plan a SLFI, or a member of an affiliated group, the members of which together hold units with a total value of at least $10,000,000 or which includes a member that is a SLFI ...

PWC, "GST/HST and QST alert: Investment plans are required to obtain investor percentages – action required by October 15, 2019", PwC Tax Insights, September 03, 2019, Issue 2019-31-- summary under Subsection 52(4) Summary Under Tax Topics- Excise Tax Act- Regulations- Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations- Section 52- Subsection 52(4) October 15 deadline under e.g. s. 30(1)(b)A4-C(ii) Timing DIPs must know where their unitholders resided or their “investor percentages” by December 31 of the particular year; however, as there are relieving rules that can apply if the information request is sent by October 15, 2019, it is strongly recommended that the information request be sent by this date. ...

PWC, "GST/HST and QST alert: Investment plans are required to obtain investor percentages – action required by October 15, 2019", PwC Tax Insights, September 03, 2019, Issue 2019-31-- summary under Subparagraph 48(1)A(b)A6(ii) Summary Under Tax Topics- Excise Tax Act- Regulations- Selected Listed Financial Institutions Attribution Method (GST/HST) Regulations- Section 48- Subsection 48(1)- Paragraph 48(1)A(b)- Element 48(1)A(b)A6- Subparagraph 48(1)A(b)A6(ii) desirability of making reconciliation election Current year election Generally, DIPs determine their provincial attribution percentage based on the default attribution point (i.e. ...

Ian Bradley, Jonathan Bright, "The Stop-Loss Rules and Corporate Reorganizations – Interpretive Challenges", Canadian Tax Journal, (2019) 67:2, 383-410-- summary under Subsection 33(2) Summary Under Tax Topics- Statutory Interpretation- Interpretation Act- Subsection 33(2) Contrary intent re pluralization of words (p. 398) The CRA claimed [in 2017-073715117] that subparagraph 40(3.5)(c)(i) can apply to a winding up of a corporation with multiple shareholders… A contrary intention [for purposes of ss. 33(2) and 3(1) of the Interpretation Act] need not be clear or unambiguous, or expressly stated in the words of the provision, as long as it can be discerned from a textual, contextual, and purposive analysis of the provisions. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Paragraph 93.1(2)(a) Summary Under Tax Topics- Income Tax Act- Section 93.1- Subsection 93.1(2)- Paragraph 93.1(2)(a) Potential net taxable income inclusion as a result of pro rata FMV rule (p. 20:37) [I]f the proportionate FMV of a member’s partnership interest is less than the member’s share of partnership income (on the basis of the allocation provided in the partnership agreement and included in the member’s income pursuant to paragraph 12(1)(l) and subsection 96(1)), the section 113 deductible amount is not sufficient to fully offset the income inclusion. ...