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Michael Matthews, "Claim Your Public Service body Rebates on Time – or Amend", Canadian GST/HST Monitor (CCH), May 2014, No. 308, p. 1.-- summary under Subsection 259(3) Summary Under Tax Topics- Excise Tax Act- Section 259- Subsection 259(3) Prior practice of carrying forward rebate claims to subsequent returns (p. 1) By strictly applying the law, the Canada Revenue Agency ("CRA") has recently effectively announced a policy change which affects all public service bodies ("PSB")…. ...

Kevin Yip, "Recent Legislation Affecting Partnerships and Foreign Affiliates – Subsection 88(1) and Section 100", Canadian Tax Journal, (2013) 61:1, 229-256, at 245-- summary under Paragraph 88(1)(e) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(e) After noting that s. 88(1)(e) can apply even if no ineligible property was transferred on a rollover basis, as s. 88(1)(e)(ii) only requires that the partnership hold ineligible property (whether directly or indirectly) at the time of acquisition of control of the subsidiary, he stated: Finance emphasizes the anti-avoidance nature of paragraph 88(1)(e), and states that this provision is intended to apply in circumstances where the "transfers are made to change the factors that may be relevant when applying the formula in subparagraph 88(1)(d(ii.1)" [fn. 49: (October 14, 2012 explanatory notes, at 27.] ...

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 Paragraph 20(1)(r) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(r) Services requirement (pp. 486-7) Consistent with contributions to other pension arrangements, employer contributions to an RCA are deductible in the year they are paid. ...

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 6(11) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(11) Consequences of SDA (p. 484) If a plan is characterized as an SDA, adverse tax consequences result. ...

– Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36-- summary under Subsection 143.4(4) Summary Under Tax Topics- Income Tax Act- Section 143.4- Subsection 143.4(4) Harshness of s. 12(1)(x) inclusion (pp. 19-20) [T]he consequences of the paragraph 12(l)(x) regime may seem especially harsh and problematic if the expenditure is a capital expenditure (e.g., where the cost of capital property is affected). ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- summary under Subsection 227(6.1) Summary Under Tax Topics- Income Tax Act- Section 227- Subsection 227(6.1) Net decrease treated as repayment under cash pool (pp.16-17) It is the position of the CRA [fn 52: …27 of IT-119R4…2006-021516117…and 990256….] which is consistent with the decision in Edward C. ...

Drache, "TFSAs as a Business", The Canadian Taxpayer, January 2, 2015 – Vol. xxxvii No. 1, p. 5.-- summary under Subsection 146.2(6) Summary Under Tax Topics- Income Tax Act- Section 146.2- Subsection 146.2(6) TFSA audit project (p.5) Sources from the tax and legal sectors of the CRA have apparently confirmed to the Financial Post that the CRA has rolled out a TFSA audit project that has become increasingly active in the past couple of years…. ...

Turner, "The New 95(2)(f.1) Carve-out Rule – Election Deadline Approaching", International Tax, CCH, 7 January 2010, No. 1974, p. 1.-- summary under Paragraph 95(2)(f.1) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(f.1) "In some respects, the new "designated acquired corporation" feature of the paragraph 95(2)(f.1) carve-out rule can be conceptualized as a tax cost bump applicable to property held by a foreign affiliate at the time control of its Canadian parent corporation is acquired. ...

Maureen Vance, "T1135 – The Saga Continues", Tax Topics, Wolters Kluwer, Number 2248, April 9, 2015, p. 1.-- summary under Subsection 233.3(3) Summary Under Tax Topics- Income Tax Act- Section 233.3- Subsection 233.3(3) Difficulties in preparing T1135s with brokerage-provided information (p. 2) Investment dealers have made considerable efforts to put systems in place to provide the information needed to complete the T1135, which was particularly challenging considering that the requirement to segregate investments on a country-by-country basis only became known when the revised form was issued last summer. ...

Michael Goldberg, "Not Quite Chicken Soup – Part II: Are Powers to Add and Remove Beneficiaries Safe for Canadian Family Trust Precedents", Tax Topics, Number 2175, November 14, 2013, p.1.-- summary under Subparagraph 55(5)(e)(ii) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(5)- Paragraph 55(5)(e)- Subparagraph 55(5)(e)(ii) Effect of power to add and remove beneficiaries (PARB) (p. 2) However, if the beneficially interested concept is applicable for purposes of subsection 55(2), then it appears that PARBs in trusts could cause those trusts to be unable to avail themselves of the exception to that provision, which might otherwise be available under paragraph 55(3) (a). ...