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The Queen – A Bridge Too FAAAR", International Tax Planning, Volume XIX, No. 1, 2013, p. 1284-- summary under Paragraph 95(2)(n) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(n) In the course of a submission that it was contrary to the scheme of the Act to apply s. 95(6)(b) to attack indirect loans to a non-resident parent, he stated: Purposes of s. 95(2)(n) (pp.1289-1290) During the taxation years in question, there was no requirement that the relevant taxpayer (i.e., the Finco owning taxpayer) must have held a "qualifying interest" (as defined in paragraph 95(2)(m))), or any economic interest at all, in the borrower Opco. ...

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 Salary Deferral Arrangement Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement "One of the main purposes…is to postpone tax" (p. 483) One might argue that a retirement arrangement was not established to defer tax where the funding of the retirement benefits was not in lieu of regular compensation or bonus, and therefore such an arrangement would not be an SDA. ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- summary under Subsection 15(2.3) Summary Under Tax Topics- Income Tax Act- Section 15- Subsection 15(2.3) Descripton of physical and notional cash pooling (pp. 2-3) [I]n general terms there are essentially two types of cash pooling arrangements [fn 1: …A representative listing…can be found…at www.rbinternational.com]: physical pooling, also known as zero-balancing, and notional pooling. ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- summary under Paragraph 212.3(10)(c) Summary Under Tax Topics- Income Tax Act- Section 212.3- Subsection 212.3(10)- Paragraph 212.3(10)(c) Cash pooling advances in the ordinary course (pp. 19-20) [I]n… 2013-0483751C6, the CRA commented that…the ordinary course of business exception could apply "when a CRIC temporarily advances funds at risk in its business (i.e., the permanent removal of such funds would have a destabilizing effect on the business of the CRIC) to a [FA Corporation] if the resulting debt is repaid in the manner required by that exemption. ...

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33-- summary under Subsection 261(21) Summary Under Tax Topics- Income Tax Act- Section 261- Subsection 261(21) CRA relief where a cash pool head account has no presence in Canada and Canco has elected (p. 24) Assume Canco…has elected to compute its Canadian tax results in US dollars. ...

Angelo Nikolakakis, "Foreign Affiliate Dumping – The New Paid-Up Capital Offset and Reinstatement Rules", International Tax (Wolters Kluwer CCH), October 2014 Number 78, p.1.-- summary under Subsection 212.3(9) Summary Under Tax Topics- Income Tax Act- Section 212.3- Subsection 212.3(9) No requirement to distribute proceeds of investment (p. 4) As noted above, the new rules would no longer require any distribution of capital in order to result in a PUC reinstatement. ...

Kenneth Snider, "US Limited Liability Partnerships – DRUPA Revisited", International Tax (Wolters Kluwer CCH), Number 77, August 2014, p. 4.-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 Two-step approach for determining whether an LLLP is a partnership (p. 6) …CRA [in 2014-0523041C6, declining to conclude that an LLLP is a partnership] restated the following two-step approach for determining the characterization of an entity for Canadian tax purposes: (1) Examine the characteristics of the foreign business association under foreign commercial law and any other relevant documents, such as the partnership agreement or other contracts; and (2) Compare these characteristics with those of recognized categories of business associations under Canadian commercial law in order to classify the foreign business association under one of those categories. ...

Xiao, "The 88(1)(d) Bump – An Update", 2013 Conference Report (Canadian Tax Foundation), pp.13:1-60-- summary under Subclause 88(1)(c)(vi)(B)(II) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c)- Subparagraph 88(1)(c)(vi)- Clause 88(1)(c)(vi)(B)- Subclause 88(1)(c)(vi)(B)(II) Cash calls on private equity investors who also are prohibited persons (pp. 13:38-39) Figure 9 Private equity (PE) buyers can raise challenging bump issues, especially funds with more complicated ownership structures…. ...

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(1.1) Summary Under Tax Topics- Income Tax Act- Section 100- Subsection 100(1.1) Purpose of s. 100(1.1)(d) (p.2) …[P]aragraph 100(1.1)(d) does not include a trust merely because it has a non-resident beneficiary. ...

PWC, "Non-Resident Employer Certification Program: Compliance Reviews and other Updates", PWC Tax Insights – Global Mobility Services, Issue 2016-47, 12 October 2016-- summary under Subsection 153(7) Summary Under Tax Topics- Income Tax Act- Section 153- Subsection 153(7) CRA indicates that qualifying non-resident employers can file T4s for their affected employees without obtaining individual tax numbers Scope of CRA review requests to qualifying non-resident employers (QNERs) (p.2) In early September 2016, the CRA started issuing review letters to certain QNERs…[to] request…the following information: the number of employees who have come to Canada during a certain period an explanation of what documentation the employer has obtained to support each employee's country of residence an explanation on how the employees are expected to be exempt from tax in Canada under a tax treaty the number of days each qualifying non-resident employee was either working in Canada, or present in Canada, including arrival and departure dates, and the employment income attributable to each employee's workdays in Canada CRA waiver of requirement for QNERs to obtain Individual Tax Numbers (ITNs) for qualifying non-resident employees (QNEEs) (pp. 2-3) As part of the Certification program, QNERs must file Canadian T4 slips for any QNEEs earning more than C$10,000 of remuneration attributable to Canadian workdays during the year. ...