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Joint Committee, "Part D of Tax Planning Using Private Corporations – “Converting Income into Capital Gains” Proposals", 2 October 2017 Joint Committee Submission-- summary under Section 246.1 Summary Under Tax Topics- Income Tax Act- Section 246.1 Listing of issues under s. 246.1 (pp. 27-31) It is unclear if, for example, there is receipt of, say, a promissory note, there is a deemed dividend on such receipt or only on subsequent distributions (principal payments). ...

Dean Landry, Colin Mowatt, "The Uncertainty Surrounding Uncertain Tax Treatments", Perspectives on Tax Law & Policy, Vol. 4, No. 3, September 2023, p. 13-- summary under Subsection 237.5(2) Summary Under Tax Topics- Income Tax Act- Section 237.5- Subsection 237.5(2) Background (p. 13) The key definitions in s. 237.5 are modelled on IFRIC 23, which indicates that if the company identifies an uncertain position and concludes it to be “not probable” that the tax authority or the courts will accept the position, it must “reflect” the effect of that uncertainty in its financial statements. ...

", Perspectives on Tax Law & Policy, Vol. 4, No. 3, September 2023, p. 1-- summary under Contractual Protection Summary Under Tax Topics- Income Tax Act- Section 237.3- Subsection 237.3(1)- Contractual Protection Narrowness of carve-outs (p. 2) Although the “contractual protection” (CP) definition has helpful carve-outs, various common arm’s-length commercial transactions, e.g., financing arrangements are not carved out and must instead be analyzed under the general framework of the reportable transaction (RT) rules. ...

PWC, "Tax Insights: Proposed changes to the alternative minimum tax ─ How will it affect individuals and trusts? ...

Xiao, "The 88(1)(d) Bump – An Update", 2013 Conference Report (Canadian Tax Foundation), pp.13:1-60-- summary under Subparagraph 88(1)(c.4)(ii) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.4)- Subparagraph 88(1)(c.4)(ii) Is debt of Target non-specified property after it is amalgamated with Bidco? ...

Angelo Nikolakakis, "Cross-Border Surplus Stripping – Stripping Bona Fide Non-Resident Purchasers", International Tax (Wolters Kluwer CCH), No. 87, May 2016, p.4-- summary under Subsection 212.1(4) Summary Under Tax Topics- Income Tax Act- Section 212.1- Subsection 212.1(4) Prejudice to Canadian shareholder of the Canadian purchaser if a non-arm's length non-resident shareholder (p. 7) [I]f a resident and a non-resident together establish the purchaser corporation as a joint venture vehicle, both are in effect penalized if it is determined that the non-resident does not deal at arm's length with the purchaser corporation…. ...

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 1401(1)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 1401- Subsection 1401(1)- Paragraph 1401(1)(c) Effect of changes to the calculation of the accumulating fund for future policies (pp. 723-4) There are significant changes to the calculation of the accumulating fund for the ETP for future policies. ...

Joint Committee, "Part D of Tax Planning Using Private Corporations – “Converting Income into Capital Gains” Proposals", 2 October 2017 Joint Committee Submission-- summary under Paragraph 84.1(2)(a.1) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(a.1) Effect of expanded rule on post-mortem transfers (pp. 8-14) The expanded s. 84.1 rule produces a greater impediment to the transfer of family businesses from one member to another, whether from one generation to another or between siblings (and during lifetime or post‐mortem), with the result that the tax system would favour third‐party sales. ...

Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Clause (h)(ii)(C) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(1)- Exempt Foreign Trust- Paragraph (h)- Subparagraph (h)(ii)- Clause (h)(ii)(C) Difficult application of (h) exception to security trust (pp. 20:90-92) The following is an example of a transfer of property by an FA to an NRT, which illustrates both (1) the analysis that should apply to determine whether the arrangement constitutes a trust, and (2) if it does apply, the difficulty in satisfying the consideration requirement of a paragraph (h) EFT. ...

Maja Stubbe Gelineck, "Permanent Establishments and the Offshore Oil and Gas Industry – Part 1", Bulletin for International Taxation, April 2016, p. 208.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Construction site clause: exemption or deeming clause (p. 211) Article 5(3) of the OECD model states that: A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months. ...