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Under subsection 148(4), the pro rata ACB associated with this disposition is $10,000 ($40,000 × $30,000/$120,000). This results in a taxable gain of $20,000 (proceeds of $30,000 − ACB of $10,000). ... As a consequence, the ACB of the policy will increase from $10,000 to $40,000 and the prorated ACB will be $10,000 ($40,000 × $30,000/$120,000), resulting in a $20,000 policy gain. ...

Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper-- summary under Subsection 111(12) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(12) A Canadian public company (Canco) will be recapitalized so that the provider of debtor-in-possession financing will end up holding 2/3 of the common shares having a fair market value equaling that of the DIP financing provided by it, and most of the balance of 1/3 of the common shares will be received by the holders of the U.S. ... -dollar terms – or less than that in Canadian-dollar terms. If the transactions are structured so that the acquisition of control by the DIP financier occurs first (or is deemed to occur first under s. 256(9)), Canco will realize the accrued FX loss on the bonds under s. 111(12). ...

Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Efficacy of payments by direction (p. 24) [W]ires are often made directly from the source of the funds (e.g. the PE [private equity] fund capital account, or the lenders' clearing account) to the ultimate destination for the funds (e.g. ...

Michel Ranger, Rhonda Rudick, "Federal and Provincial Tax Considerations Relating to Non-Resident Investment in Canadian Real Estate", 2019 Conference Report (Canadian Tax Foundation), 32:1 – 39-- summary under Paragraph (a) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxable Canadian Property- Paragraph (a) Quebec taxation of income from specified immovable property [N[on-resident inter vivos trusts that own immovable property in Quebec and that earn rental income from that property (that is, passive rental income that does not constitute business income earned through an establishment in Quebec) are also subject to provincial tax in Quebec. ... Property income derived from the rental of specified immovable properties must be computed separately from income from any other sources of a specified trust. … Double taxation on a disposition of specified immovable property On a disposition of a “specified immovable property,” [by] a non-resident inter vivos trust … the taxable portion of the capital gain (and recaptured depreciation, if any) will be subject to federal income tax and the surtax at a combined rate of 48.84 percent (resulting in an effective tax rate of 24.42 per-cent on the capital gain). ...

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). ...

…In another example, based on the Bank of Scotland case [fn 233: … Ministre de l’Econimie v. ... …[T]he analysis in the commentary appears to suggest that the PPT could also apply to transactions or arrangements like those in Del Commercial Properties [fn 239: C Memo 1999-411 • aff'd 251 F.3d 210 (DC Cir. 2001), denying treaty benefits on the basis of a domestic substance-over-form doctrine….] ... [fn 253: … Yanko-Weiss v. Holon Assessing Office (2007), 10 TLR 524 (Tel Aviv-Yafo DC) denying treaty benefits on the basis of an implicit anti-abuse principle.] ...

Jim Kahane, Uros Karadzic, Simon Létourneau-Laroche, "A Fresh Look at Retirement Compensation Arrangement: A Flexible Vehicle for Retirement Planning", Canadian Tax Journal (2013) 61:2, 479 – 502.-- summary under Subsection 207.6(5) Summary Under Tax Topics- Income Tax Act- Section 207.6- Subsection 207.6(5) Resident contribution rule (p. 491) Under these rules, if a newcomer to Canada remains a member of his or her home-country pension plan for more than five years, the foreign pension plan may still be considered an RCA for Canadian tax purposes. ... [fn 63: Subsection 32.1(1)] … ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- summary under Subsection 90(15) Summary Under Tax Topics- Income Tax Act- Section 90- Subsection 90(15) Exclusion for loans to NR subs of related Canadian corporations (pp. 11-12) Consider…the structure…in which BVCo 1 [a NR sub of the immediate U.S. parent of Canco 1] is the head account holder. … Since BVCo 1 does not deal at arm's length with Canco 1 and is not a controlled foreign affiliate of Canco 1, BVCo 1 is a specified debtor in respect of Canco 1. ...

Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) Whether specific tracing or blended aggregate approach should be applied in determining s. 39(2) gain or loss on FX debt partial repayments (p. 18:19) Aside from indicating the exchange rate(s) to be used, subsection 261(2) does not specify which particular advance or draw on an indebtedness is considered to be repaid for the purposes of determining the amount of any foreign exchange gain or loss that arises under subsection 39(2). Depending on whether one uses a specific linking or tracing approach, or whether one uses the pragmatic and probably more common approach of determining the unpaid balance in Canadian currency on the basis of a buildup of the applicable relevant spot rates for historical transactions, the partial repayment of a foreign-currency-denominated indebtedness could potentially yield a significantly different foreign exchange result to the debtor. … It does not appear that the CRA has publicly commented on whether a specific tracing or blended aggregate approach is acceptable for the purposes of determining a gain or loss under subsection 39(2). ...

Raj Juneja, Pierre Bourgeois, "International Tax Issues That Get in the Way of Doing Business", 2019 Conference Report (Canadian Tax Foundation), 36:1 – 42-- summary under Subsection 212.3(1) Summary Under Tax Topics- Income Tax Act- Section 212.3- Subsection 212.3(1) FAD rules apply even where no debt dumping or surplus stripping involved The foreign affiliate dumping (FAD) rules were intended to target two types of transactions: debt dumping (for example, Canadian Opco borrows to acquire preferred shares of a non-resident Opco subsidiary of its non-resident parent and receives (s. 113(1)(a)) exempt dividends on those shares) (pp. 36:2-3) surplus stripping (for example, Canadian Opco, with distributable cash but whose shares have low paid-up capital (PUC), purchases (or subscribes for) such preferred shares) (pp. 36: 3-4) The principal issue with the FAD rules is that one general rule was drafted to target these two different abuses, and without any purpose test or attempt to narrow the types of investments that are caught, so that they apply where the CRIC makes an investment in an FA regardless of whether any debt dumping or surplus stripping occurs (p. 36:5). For example, they apply where the Canadian subsidiary uses cash on hand to invest in common shares of a wholly owned non-resident Opco for use in its foreign active business – even though there is no debt dumping or surplus stripping involved (p. 36:5). ...