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Preliminarily to a proposed butterfly split-up of DC between TC1 and TC2, the note owing to the estate, and the DC preferred shares, would be distributed on a 50-50 basis under s. 107(2) to the two testamentary trusts, from them on a s. 107(2) rollover basis to the two respective children, and by each of them to her or his TC on a s. 85(1) rollover basis – and similarly, the DC common shares would be distributed on a s. 107(2) rollover basis by the Trust to the two children, and by them on a s. 85(1) rollover basis to their respective TCs. ... Summary of 2023 Ruling 2022-0957491R3 F under s. 55(1) – distribution. ...

These are additions to our set of 3,011 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 ½ years of releases of such items by the Directorate. ... Bundle Date Translated severed letter Summaries under Summary descriptor 2001-05-25 10 May 2001 Internal T.I. 2001-0065827 F- FINES + PENALTIES- INTÉRETS ET PÉNALITÉS Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose criteria of public policy and inevitability in IT-104R2 no longer applicable re fines and penalties/ provincial interest and penalties are non-deductible Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(t) s. 18(1)(t) enacted for greater certainty 10 May 2001 Internal T.I. 2001-0065737 F- ÉCHANGE DE BIEN- 13(4) Income Tax Act- Section 13- Subsection 13(4)- Paragraph 13(4)(d) s. 13(4)(d) provides that the recapture which was avoided, is subtracted from the UCC of the replacement property, and does not eliminate class continuity 10 May 2001 Internal T.I. 2001-0065817 F- WEB SITE- SITE INTERNET Income Tax Regulations- Schedules- Schedule II- Class 8- Paragraph 8(i) general (non-software or computer) capital expenditures on website development generally includible in Class 8(i) 2001-05-11 18 April 2001 External T.I. 2001-0074995 F- Indemnité journalière de grossesse de France Income Tax Act- Section 3- Paragraph 3(a) French maternity allowances were taxable 27 April 2001 External T.I. 2000-0057055 F- INTERETS/OBLIGATIONS A COUPONS DETACHES Income Tax Regulations- Regulation 7000- Subsection 7000(2)- Paragraph 7000(2)(b) application of Reg. 7000(2)(b) to acquisition of bond stripped of interest coupons 2001-04-27 17 April 2001 External T.I. 2001-0074915 F- Fonds commun de placement- Disposition Income Tax Act- Section 248- Subsection 248(1)- Disposition change in taxable account through which MFT units are held does not entail their disposition ...

11 December 2024- 11:26pm CRA indicates that it will administer the GMTA in accordance with OECD administrative guidance where Finance has intimated that the GMTA will be amended to catch up Email this Content CRA indicated that as new OECD administrative guidance is released, the DST and Global Tax Section of CRA will consult with the Department of Finance to determine, on a case-by-case basis, how such guidance should be handled – whether there is a pending amendment to the Global Minimum Tax Act (GMTA) or whether CRA will apply the new guidance to inform its interpretation of the existing GMTA provisions. ... CRA indicated that it has consulted with Finance and, in light of likely further amendments, it will administer the provisions of the GMTA to achieve what the OECD administrative guidance clarifies should be the outcome – that is, the constituent entity covered taxes paid by the upper-tier entity being pushed down to the CE. ...

The penalty recommendations by the Transfer Pricing Review Committee have declined from 51% (for referrals received up to 2012) to 44% thereafter – there is more and better contemporaneous documentation. ... November 2016 Toronto Centre Canada Revenue Agency & Tax Professionals Seminar on International Tax Issues. ...

Act – and, in any event, the real complaint of CRA was not that the gain was (temporarily) deferred, but that when the gain was realized, the allocation rules caused that gain to mostly not be taxed, which had nothing to do with the purpose of s. 85(1). ... The Queen, 2017 BCCA 3 under s. 245(4) and Statutory Interpretation – Inserting words. ...

14 May 2017- 11:43pm CRA indicates that the GST gross negligence penalty can be levied on amounts that are not attributable to gross negligence Email this Content Although the ETA gross negligence penalty has essentially the same precondition – referencing “knowingly, or under circumstances amounting to gross negligence, makes or participates in, assents to or acquiesces in the making of a false statement or omission in a return [etc.]” – as ITA s. 163(2), the mechanics of computing the penalty (of 25% rather than 50%) differ. ...

These (and the other full-text translations covering the last 3 ½ years of CRA releases) are subject to the usual (3 working weeks per month) paywall. Bundle Date Translated severed letter Summaries under Summary descriptor 2014-05-07 2 April 2014 External T.I. 2014-0521041E5 F- Application de 13(7.1) Income Tax Act- Section 13- Subsection 13(7.4) general requirements for s. 13(7.4) to apply Income Tax Act- Section 13- Subsection 13(7.1) no s. 13(7.4) election required where s. 13(7.1) applies 2 April 2014 External T.I. 2012-0473151E5 F- Limitation du coût de location d'un véhicule Income Tax Act- Section 67.3 GST ITCs included under element E of formula Income Tax Act- Section 248- Subsection 248(16) GST ITCs constitute a “reimbursement” for car lease expense limitation purposes 11 March 2014 Internal T.I. 2013-0513221I7 F- Stock options General Concepts- Fair Market Value- Options stock options with no in-the-money value could have nil FMV Income Tax Act- Section 52- Subsection 52(1) s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares Income Tax Act- Section 15- Subsection 15(1) double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder Income Tax Act- Section 56- Subsection 56(2) s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder Income Tax Act- Section 56- Subsection 56(4) implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder Income Tax Act- Section 248- Subsection 248(28) s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 Income Tax Act- Section 9- Timing no s. 9(1) income inclusion from consultant being granted stock options until exercise 3 April 2014 External T.I. 2013-0512371E5 F- Qualification des montants gagnés au jeu de poker Income Tax Act- Section 3- Business Source/Reasonable Expectation of Profit on-line poker winnings were from more than a pastime 25 April 2014 External T.I. 2013-0515621E5 F- Frais de voyage / Travelling expenses Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) benefit where employer pays costs of friend to accompany employee on training trip 2014-04-30 27 March 2014 External T.I. 2014-0524851E5 F- Deemed year-end and CPCC status Income Tax Act- Section 249- Subsection 249(3.1) Ekamant: s. 251(5)(b) does not vitiate actual control by share owner Income Tax Act- Section 251- Subsection 251(5)- Paragraph 251(5)(b) sub of public corporation does not become CCPC until time of its actual acquisition of control ...

This is accomplished by the Parent of Sub2 exchanging its common shares of Sub2 under a s. 86 reorg for new common shares and (non-voting redeemable retractable) Sub2 Preferred Shares – and then transferring the Sub2 Preferred Shares under s. 85(1) to Sub1 under s. 85(1) in exchange for common shares of Sub1. ... Summary of 2016 Ruling 2015-0623731R3 under s. 55(3)(a), s. 80(1) – forgiven amount and s. 86(1). ...

In addition “redeeming the … preferred shares held by Ms. X crystalizes the additional RDTOH so that it is an asset for the purposes of the butterfly, which allows for a more equitable distribution of assets on the single-wing butterfly of DC2’s assets.” ... Summaries of 2017 Ruling 2016-0674681R3 under s. 55(1) – distribution and s. 55(3.1)(a). ...

This expanded rule might apply, for example, where the CRIC is a 9% shareholder of Canco with the other 91% held by Canco’s non-resident parent and the CRIC lends to a non-resident subsidiary of Canco – provided that the CRIC does not deal at arm’s length with Canco as a factual matter. ... To mention only one example, if an acquisition of control of a foreign parent (“FP”) holding Canco1 (which, in turn, holds Canco2) is followed as part of the series of transactions by a transfer of a foreign affiliate between the two Cancos, the safe harbour is unavailable – unless, following such acquisition of FP, FP first transfers the Canco1 shares it owns to a new Canadian corporation and a new Canadian company is also inserted between Canco1 and Canco2. ...