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Xiao, "The 88(1)(d) Bump – An Update", 2013 Conference Report (Canadian Tax Foundation), pp.13:1-60-- summary under Subparagraph 88(1)(c.2)(i) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.2)- Subparagraph 88(1)(c.2)(i) Parent relatedness to mooted specifed person from moment of its incorporation if not a shelf corp. ...

Kevin Yip, "Recent Legislation Affecting Partnerships and Foreign Affiliates – Subsection 88(1) and Section 100", Canadian Tax Journal, (2013) 61:1, 229-256, at 237-- summary under Subsection 5905(5.2) Summary Under Tax Topics- Income Tax Regulations- Regulation 5905- Subsection 5905(5.2) Proposed regulation 5905(5.2) is conceptually similar to paragraph 111(4)(c), which reduces the ACB of certain capital property of a Canadian corporation to the extent that the ACB exceeds the FMV of the property immediately before an acquisition of control. ...

Nitikman, "Section 247 – Secondary Adjustments, Deemed Dividends, Repatriation and Interest", International Tax Planning (Federated Press), Vol. ...

Jessica Fabbro, "Dispositions of Partnership Interests – Navigating the Amendments to Section 100 of the Income Tax Act", CCH Tax Topics, No. 2162, August 15, 2013, p. 1-- summary under Subsection 100(1.3) Summary Under Tax Topics- Income Tax Act- Section 100- Subsection 100(1.3) Reason for rule (p. 3) Subsection 100(1.3) applies where the purchaser of the partnership interest is a non-resident and partnership property is used, both immediately before and after the acquisition of the partnership interest, in carrying on business in Canada through a permanent establishment and that property represents 90% or more of the fair market value of all the assets of the partnership. ...

Timothy Hughes, Matias Milet, Marc Richardson-Arnould, "Private Equity Funds – Selected Canadian Tax Issues", Tax Management International Journal, 2016, p.84-- summary under Paragraph 115.2(2)(b) Summary Under Tax Topics- Income Tax Act- Section 115.2- Subsection 115.2(2)- Paragraph 115.2(2)(b) Restrictions on s. 115.2 safe harbour (p. 86) The safe harbour contains a number of restrictions. ...

Timothy Hughes, Matias Milet, Marc Richardson-Arnould, "Private Equity Funds – Selected Canadian Tax Issues", Tax Management International Journal, 2016, p.84-- summary under Paragraph (d) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Taxable Canadian Property- Paragraph (d) Goodwill fluctuations relative to real estate may potentially taint private equity investments (p. 86) Private equity funds currently invest predominantly in Canadian bio-tech, clean-tech, and high-tech companies, the shares of which are unlikely to constitute TCP. ...

Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50-- summary under Subsection 307(1) Summary Under Tax Topics- Income Tax Regulations- Regulation 307- Subsection 307(1) Overview/purpose of accumulating fund (p. 709) The accumulating fund is intended to represent the savings element in the policy and has historically been the greater of (1) the cash surrender value and (2) the present value of future benefits less the present value of future premiums payable under the policy (effectively the reserve that can be claimed by the insurer in respect of the policy). ...

Kevin Wark, Michael O'Connor, "The Next Phase of Life Insurance Policyholder Taxation is Nigh", Canadian Tax Journal (2016) 64:4, 705 - 50-- summary under Paragraph 308(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 308- Subsection 308(1)- Paragraph 308(1)(b) Effect of net cost of pure insurance on policy ACB (pp. 733-4) The NCPI of a policy reduces the ACB of policies last acquired after December 1, 1982 [f.n. 114: The total of all annual NCPI charges reduces the ACB of the policyholder's interest in a policy by virtue of element L of the definition of "adjusted cost basis" in subsection 148(9). ...

Joint Committee, "Subsection 55(2) Amendments – Follow-Up to Our Meeting with Canada Revenue Agency", 19 January 2018 Joint Committee Submission to Finance respecting s. 2015 s. 55(2) Amendments including appended 20 April 2017 letter to Randy Hewlett on such Amendments-- summary under Subsection 55(2) Summary Under Tax Topics- Income Tax Act- Section 55- Subsection 55(2) Submission to CRA on s. 55(2.1)(b) purpose test, s. 55(2)(c), s. 55(2.1)(c), s. 55(2) Pt IV exception The April 20, 2017 letter to the Income Tax Rulings Directorate identified a number of issues respecting the Amendments including in the following contexts (on which detailed slides were provided): The interpretation of the new s. 55(2.1)(b) purpose tests and their impact on dividends where capital gains reduction was never a motivation The timing and scope of the deemed gain under s. 55(2)(c) and the interaction of the deeming rule with other ITA provisions The application of the Amendments to safe income capitalization transactions, including complexities respecting the cost of a stock dividend and the impact on computing the capital dividend account The interpretation of the Pt IV tax exception in s. 55(2) and compliance issues under Ottawa Air Cargo. ...

Alan Kenigsberg, "Changes to Tax Treatment of ILPs under the ETA", Sales Tax, Customs & Trade, Volume XV, No 2, Federated Press, 2018, p.9-- summary under Subsection 217.1(1) Summary Under Tax Topics- Excise Tax Act- Section 217.1- Subsection 217.1(1) Aborted proposal to extend qualifying taxpayer rules to non-resident LPs (p. 12) When the Department of Finance first announced that it was looking into drafting new rules for ILPs and requested comments, it suggested that the self-assessing rules may be extended to limited partnerships where the value of the assets of the partnership in which one or more persons resident in Canada have a beneficial interest, is equal to or exceeds $10 million and is equal to or exceeds 10% of the total value of the assets of the partnership. ...