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Conference summary
27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6 - TOSI – Excluded Shares & Related Business -- summary under Excluded Shares
27 November 2018 CTF Roundtable Q. 10, 2018-0780081C6- TOSI – Excluded Shares & Related Business-- summary under Excluded Shares Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(1)- Excluded Shares exclusion for investment business or passive amounts not derived from a related business 29 May 2018 STEP Roundtable Q.7, 2018-0744031C6 indicated that the shares of a corporation that did not generate business income (e.g., a corporation that generated rents that, given the level of activity, constituted income from property) cannot qualify as excluded shares, whereas in Examples 8 and 12 of the Guidance on the Application of the Split Income Rules for Adults (December 13, 2017), shares of a corporation earning income from passive investment assets qualified as excluded shares. ...
Conference summary
25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6 - Curr Use & 95(2)(a)(ii)(B) & (D) -- summary under Subclause 95(2)(a)(ii)(D)(I)
25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Subclause 95(2)(a)(ii)(D)(I) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(D)- Subclause 95(2)(a)(ii)(D)(I) acquisition of shares that were not excluded property qualified under current use test FA Finco (a foreign affiliate of Canadian Parent) lends to FA Holdco (a Delaware subsidiary of Canadian Parent), which uses the borrowed money to acquire all of the shares of FA Target, which are not excluded property. ...
Conference summary
25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6 - Curr Use & 95(2)(a)(ii)(B) & (D) -- summary under Subclause 95(2)(a)(ii)(D)(III)
25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Subclause 95(2)(a)(ii)(D)(III) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(D)- Subclause 95(2)(a)(ii)(D)(III) in light of the current-use test, borrowed money used to acquire shares that were not excluded property could satisfy s. 95(2)(a)(ii)(D) FA Finco (a foreign affiliate of Canadian Parent) lends to FA Holdco (a Delaware subsidiary of Canadian Parent), which uses the borrowed money to acquire all of the shares of FA Target, which are not excluded property. ...
Technical Interpretation - External summary
4 March 2025 External T.I. 2025-1053731E5 - DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement -- summary under Subsection 87(8.4)
4 March 2025 External T.I. 2025-1053731E5- DOF Explanatory Notes on Subsections 87(8.4) & (8.5) – Inconsistent Statement-- summary under Subsection 87(8.4) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(8.4) the Explanatory Notes on s. 87(8.4) partially conflated it with s. 87(8) The Explanatory Notes to ss. 87(8.4) and (8.5) provide: New subsections 87(8.4) and (8.5) allow taxpayers to elect for dispositions of taxable Canadian property (“TCP”) that is shares of a corporation or an interest in a partnership or trust to occur on a tax-deferred (“rollover”) basis, where the disposition results from a foreign merger that meets certain conditions. ...
Conference summary
18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6 - 2015 STEP Q2 Meaning of Graduated Rate Estates -- summary under Graduated Rate Estate
18 June 2015 STEP Roundtable Q. 2, 2015-0572091C6- 2015 STEP Q2 Meaning of Graduated Rate Estates-- summary under Graduated Rate Estate Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Graduated Rate Estate one estate even if multiple wills (see also summary of initial response at 19 June 2015 STEP Roundtable, oral Q.2(a)) If an estate for a deceased who passed away after 2015 is under administration in its first 36 months, will it be considered a graduated rate estate in its entirety, even if there are two wills. ...
Article Summary
Joel A. Nitikman, "Rectification: Specific Intent? General Intent? What is the Test? – Part II", Tax Topics, Wolters Kluwer, No. 2274, October 8, 2015, p.1. -- summary under Rectification & Rescission
– Part II", Tax Topics, Wolters Kluwer, No. 2274, October 8, 2015, p.1.-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Test is one simply of true intention, not specific intent (pp. 3-4) In Juliar,…[t]he key passages from the Court of Appeal are these:… [I]t is possible,, even probable, that no one mentioned income tax throughout the nine or 10 months in issue. ... If there is no requirement for due diligence, it means that rectification is available even when there is a mistake — even a negligent mistake [f.n. 10. ... Coutts & Co, [2006] EWHC 1502 (Ch.) at paragraph 11, the Courts granted rectification even though the mistake was caused clearly by a professional advisor's negligence. ...
Article Summary
PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020 -- summary under Investment Limited Partnership
PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020-- summary under Investment Limited Partnership Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Investment Limited Partnership Meaning of “principal activity” A person’s “principal activity,” as discussed … in College of Applied Arts … depends on how important a particular activity assists the person in achieving its overall business objectives and goals when compared to its other business activities. ...
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 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
Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017 -- summary under Section 96
Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Distinction between employee and partner/fixed distribution entitlement (5-20) [I]gnoring for the present section 2(3)(b) [the same as Partnerships Act (Ont.), s.3.3(b)], it was frequently held prior to the 1890 Act that employees who were remunerated by reference to the profits of a business were not partners therein, at least where it appeared from the agreement that no partnership was intended. ... & C. 867; Ex p. Chuck (1832) 8 Bing. 469; Gilpin v. Enderby (1824) 5 B. & A. 954. In such a case, an express term in the agreement negativing any implication of partnership may be ineffective vis-a-vis third parties, such as HMRC: see Fenston v. ...