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See Taitz & Millar, ‘‘The GST and National Religious Organizations – Selected Issues”, GST & Commodity Tax (Carswell), Vol. ... The schedule to that Notice of Ways and Means Motion to Amend the Excise Tax Act contained the following text with respect to section 155: “ Section 155 — Non-Arm's Length Supplies by Public Sector Bodies: Section 155 provides an anti-avoidance rule that deems certain non-arm's length supplies made for less than fair market value to be made for fair market value. ... A determination of the LP’s primary purpose would generally reflect its main or fundamental purpose at the time it was established – and may be reassessed later on. ...

The CRA requires that form T2075 be filed twice – this is noted at the top of the form. ... A forgiven amount at any time is determined by the formula A – B, under that definition in s. 80(1). ... Official Response 15 June 2022 Roundtable, 2022-0924791C6- STEP 2022 – Q18- McNeeley et al v. ...

Potential abuse of integration principle However, the D & D Livestock case illustrates how s. 55(2) can be instrumental in not only preventing the duplication of taxes, but might also be instrumental in generating ACB that is unsupported by taxed corporate income. ... D & D Livestock addressed We will not go over the facts of D & D Livestock in detail. ... Some people have been wondering about the fact that in D & D, there was a sale that was contemplated and whether the changes to proposed s. 55(2) would be limited to circumstances where a potential buyer has been identified or where there is a potential sale as part of a series in the traditional sense or in the extended sense under s. 248(10). ...

(a) In the first situation, since the down payment was fully paid by A, A will be considered to have made a gift of $50,000 to B at the time of purchase (50% × $100,000). ... Instead, could the ACB of each be allocated as follows: A: $250,000 ($100,000 + (50 % × $300,000)) B: $150,000 (50 % × $300,000) b) In the second situation, in CRA's opinion, pursuant to Art. 1015 C.C.Q. of the Civil Code, will each be required to report the following proceeds of disposition and ACB in 2021 A (50 %): $350,000- $200,000 B (50 %): $350,000- $200,000 Is it then reasonable to conclude that the $100,000 priority payment to A actually includes the repayment by B of a loan made to B by A at the time of purchase, being 50% of the $100,000 down payment, or $50,000? ... The CRA is of the view that the word "consideration" in the phrase "fair market value of any consideration … received by the donee for the disposition … of the security" in paragraph 118.1(13)(c) must be given the broad meaning generally accepted in the jurisprudence. ...

S. 46(1) also does the same to proceeds of disposition – the greater of $1,000 or the amount otherwise determined. ... It is calculated first at the entity level – and nothing in this scenario would alter the nature of that calculation – and then the Canadian income inclusion under s. 91(1) is then determined on a share-by-share basis – again nothing in this scenario would alter the nature of that calculation. ... In the scenarios that are presented – either that the daughter disposes of the property within 24 months of her father’s death or she waits for more than 24 months – in both situations, because the farm has been owned continuously by Mr. ...

Element C in the s. 6(2) formula appears to contemplate that the cost of the automobile to a person (Holdco) related to the employer is to be taken into account – but 2014-0529991E5 appears to indicate that the leasing cost to Opco should instead be used. ... The formula in subsection 6(2) is worded as follows: A/B × [2% × (C × D) + 2/3 × (E – F)] Element C of this formula represents the cost of the automobile to the employer or to a person related to the employer if either of them owns the vehicle at any time in the year. ... Official response 6 October 2017 APFF Roundtable Q. 14, 2017-0720321C6 F- GAAR & 21-year rule planning Q.15 Step-up of goodwill on loss restriction event The sole asset of a corporation sold to a 3 rd party is goodwill with a fair market value of $200,000. ...

Preliminary response The conclusion in 2013-0509111E5 – that s. 94(2)(t) applied, but not in respect of the original transfer of shares by Corp X to Trust A – still stands. ... It serves to report information about the trust itself, but also information that affects the taxation of persons who happen to have some connection to the trust – beneficiaries, settlors, and contributors. ... This is not a new interpretation – it is consistent with 2000-0056385 F. ...

Prud'homme: We basically see two types of files concerning regular dividends – either there is safe income or there is not. ... In this scenario – where Canada maintains full ability to tax – are the businesses, undertakings and activities of B Co carried on in Canada? ... ATI is determined by the formula A + B – C, and A is determined by the formula D – E. ...

Can “actively engaged on a regular basis” in s. 120.4(1) – split income – (c)(ii)(D) be interpreted in the same way as "actively engaged on a regular and continuous basis" as defined in IT-349R3 and IT-268R4 (but with necessary adaptations to reflect the farming business context of the latter)? ... Official Response 9 October 2015 APFF Roundtable Q. 20, 2015-0595681C6 F- Avantages imposables / dépenses d’entreprise. ... Under the definition of “aggregate investment income” in s. 129(1), the corporation would have investment income of $34,000, comprised of a taxable capital gain of $18,000 and property income of $40,000 (i.e., $14,000 + $12,000 + $24,000-$10,000) minus the dividend deduction from taxable income of $24,000. ...

The Queen,[FN13: 2009 TCC 394 (" Richer ").] the Tax Court of Canada held that a debt is settled or extinguished when the creditor and debtor agree to fix or modify their existing rights and obligations, which occurs in January 2023. ... (" Leblond ").] the Court ordered the Deputy Minister of Revenue of Quebec to split an assessment, i.e., that the tax liability for the pre-proposal period of the arrangement was to be included in the provable claims for the proposal. ... In determining whether income is derived from property that is used or held principally for the purpose of gaining or producing income from an active business, the comments in paragraph 6 of IT-73R6 may be helpful: “6. […] It is a question of fact whether a property is used principally in an active business. ...