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Sherman, "GST Tidbits – Backdating of Voluntary Registrations by 30 Days", GST & HST Times, Release No. 280C – March 2013-- summary under Subsection 240(1) Summary Under Tax Topics- Excise Tax Act- Section 240- Subsection 240(1) At CRA's annual GST/HST meeting with the Canadian Bar Association Commodity Tax section on February 23, 2012, CRA stated in Question 48: For a voluntary GST/HST registration the CRA will accept an effective date of registration that is within 30 days of the date when the registration was made, regardless of the method of registration (online, telephone, or paper). ...

Allan Lanthier, "Tax relief for family business transfers: A legislative fiasco – Part I / Tax relief for family business transfers: A legislative fiasco – Part II", Canadian Accountant, 8 July 2021 (Part I) and 9 July 2021 (Part II)-- summary under Paragraph 84.1(2)(e) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) Overview Bill C-208 generally provides that an individual selling qualified small business shares or shares of a family farm or fishing corporation to a corporation controlled by the individual’s children or grandchildren who are at least 18 years of age will benefit from capital gains treatment rather than a s. 84.1 deemed dividend provided that such purchaser does not dispose of those shares for at least 60 months. ... Example of strip Emily transfers her shares of a small business corporation (Petco) with nominal tax basis and paid-up capital to a Newco- in which her daughter owns nominal value special voting shares giving her voting control, and Emily owns the balance of the equity – in consideration for a promissory note, which is repaid over the next five years with intercorporate dividends received by Newco from Petco. ... Furthermore, the math in the formula is wrong – even if it were effective, it would only eliminate the deduction at taxable capital levels of $510 million, not $15 million. ...

Rob Kreklewetz & Stuart Clark, "Incoterms® 2020 Changes Incoming! ... DAT becomes DPU – … Incoterms® 2020 now redefines DAT (Delivered at Terminal) as DPU (Delivered at Place Unloaded) … to reflect the fact that delivery could be at any place rather than just at a terminal. Security Requirements – Incoterms® 2020 also expands the terms related to obtaining security clearances for the shipment of goods. … ...

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. ...

PWC, "Tax Insights: Investment limited partnerships ─ GST/HST & QST filing obligations", Issue 2020-27, May 04, 2020-- summary under Subsection 225.4(6) Summary Under Tax Topics- Excise Tax Act- Section 225.4- Subsection 225.4(6) Addition of ILPs to SLFI world Most Canadian resident investment limited partnerships (ILPs) will be considered to be a Selected Listed Financial Institution (SLFI), starting January 1, 2019 (i.e. the 2019 fiscal year). ...

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). ...

Roderick I’Anson Banks, "Lindley & Banks on Partnership", (Sweet & Maxwell, 20th Ed.) 2017-- summary under Section 6 Summary Under Tax Topics- Other Legislation/Constitution- Ontario- Partnerships Act- Section 6 Effect of s. 5 of the Partnership Act 1890 (U.K.) ...

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. ...

Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part II", CCH Tax Topics, No. 2135, 7 February 2013, p. 1 at p. 4:-- summary under Subsection 56.4(6) Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(6) Paragraphs 56.4(6)(e) (arm's length employee exception) and 56.4(7)(d) ("goodwill amount" and "disposition of property" exceptions) provide that no proceeds can be received or receivable by the individual granting the RC. ...

Mark Woltersdorf, "Restrictive Covenants – The Final Chapter (For Now) – Part I", CCH Tax Topics, No. 2132, 17 January 2013, p. 1 at p. 3-- summary under Eligible Interest Summary Under Tax Topics- Income Tax Act- Section 56.4- Subsection 56.4(1)- Eligible Interest It is uncertain why the above definition [of eligible interest] excludes shares of a corporation where, for example, that corporation owns all of the shares in the capital stock of two or more subsidiary corporations. ...