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Folio Summary
S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Subparagraph (b)(iii)
S3-F10-C3- Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subparagraph (b)(iii) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(iii) Any increase in value traceable to plan property acquired under a swap transaction is subject to advantage tax 3.24 A swap transaction is expressly included in the list of transactions that are treated as an advantage. ...
Folio Summary
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Section 262
S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Section 262 Summary Under Tax Topics- Income Tax Act- Section 262 OTC systems not included 1.18 Over-the-counter (OTC) quotation systems, such as the OTC Bulletin Board and OTC Link ATS (formerly Pink Sheets) in the United States, are not designated stock exchanges. ...
Folio Summary
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Paragraph 4900(1)(b)
S3-F10-C1- Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Paragraph 4900(1)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 4900- Subsection 4900(1)- Paragraph 4900(1)(b) Back-dating rule effective for Reg. 4900(1)(b) purposes 1.24 The post-amble of the public corporation definition in subsection 89(1) allows a new corporation to elect to be deemed to have been a public corporation since its date of incorporation.... ...
Folio Summary
S3-F10-C2 - Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Subsection 207.01(4)
S3-F10-C2- Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subsection 207.01(4) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(4) Inclusion of units held in relative's RRSP 2.12 In determining whether an individual has a significant interest in a trust, any units of the trust held in registered plans of family members who are related to the individual must be counted. ...
Folio Summary
S3-F10-C2 - Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs -- summary under Subsection 207.06(2)
S3-F10-C2- Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs-- summary under Subsection 207.06(2) Summary Under Tax Topics- Income Tax Act- Section 207.06- Subsection 207.06(2) Factors relevant to waiver of tax 2.36 Subsection 207.06(2) gives the Minister the authority to waive or cancel all or part of the 50% tax on prohibited investments or the 100% advantage tax in appropriate circumstances. ...
TCC (summary)
Mac & Mac Hydrodemolition v. The Queen, 2017 TCC 256 (Informal Procedure) -- summary under Scientific Research & Experimental Development
In denying the taxpayer’s SR&ED claims, Graham J stated (at paras 7, 8, 9 and 10): Mac & Mac’s claims … do not meet the last test [in Northwest Hydraulic.] ... Mac & Mac kept a set of handwritten notes. … There is simply no way that someone, even someone very experienced in the industry, could hope to replicate or confirm Mac & Mac’s results from these notes. A spreadsheet … provided more detail than the notes. However, it was prepared after the fact for the purpose of supporting the SR&ED claim and still did not contain the level of detail I would have expected. … As noted … in Highweb & Page Group Inc. v. ...
Decision summary
Wiltonpark Ltd & Ors v Revenue & Customs Commissioners, [2016] EWCA Civ 1294 -- summary under Paragraph (a)
Wiltonpark Ltd & Ors v Revenue & Customs Commissioners, [2016] EWCA Civ 1294-- summary under Paragraph (a) Summary Under Tax Topics- Excise Tax Act- Section 123- Subsection 123(1)- Financial Service- Paragraph (a) fee charged by club for encashing vouchers was in economic reality for access to club The self-employed lap dancers at the appellants’ clubs often would accept vouchers from customers, who had run out of cash, in exchange for their services. ... In accepting the HMRC’s position that the vouchers were consideration for taxable supplies of club facilities provided by the appellants to the dancers, Richards LJ stated (at paras 42, 48 and 50): …[T]he critical point in my judgment is whether it is right to treat, as part of the services supplied in return for the commission payable on encashment of vouchers, the provision of the club's facilities to the dancers to enable them to obtain income from non-cash customers. … … [A] commission of 20% for the encashment of a voucher, even with the benefits of inclusion in the scheme, is on the face of it very high, particularly as the appellants ran, as they knew, a very low credit risk. … [T]he UT's analysis that the provision of the club's facilities forms part of the consideration for the commission on encashment of the vouchers is a legitimate interpretation of the constituent parts of the services supplied by the appellants in return for the commission. ...
Conference summary
25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6 - Curr Use & 95(2)(a)(ii)(B) & (D) -- summary under Clause 95(2)(a)(ii)(B)
25 November 2021 CTF Roundtable Q. 15, 2021-0911921C6- Curr Use & 95(2)(a)(ii)(B) & (D)-- summary under Clause 95(2)(a)(ii)(B) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(ii)- Clause 95(2)(a)(ii)(B) application of current use test under s. 20(1)(c) FA Finco, a foreign affiliate of Canadian Parent, lends money to FA Acquireco LLC (a US fiscally-transparent subsidiary of FA Holdco (which is a non-transparent Delaware subsidiary of Canadian Parent) to acquire all the shares of FA Target LLC (also fiscally transparent), which is merged into FA Acquireco LLC (renamed “Mergeco LLC”). ... Since Mergeco is a disregarded entity, Reg. 5907(1) – earnings – (a)(iii) requires such earnings to be computed under Part I for such purposes. This wording engages the current use test under s. 20(1)(c) – which should be satisfied since the Mergeco property would be used in an active business. ...
Technical Interpretation - External
1 November 1993 External T.I. 9317770 - APFF — Acquisition de contrôle — Mandat — Lien dépendance — PCGR
1 November 1993 External T.I. 9317770- APFF — Acquisition de contrôle — Mandat — Lien dépendance — PCGR Unedited CRA Tags 256, 251, 249 ACQUISITION DE CONTROLE Richard S. ... Ce dernier vend ses actions à C. b) La propriété de la Corporation X est détenue par un groupe de 25 employés-actionnaires, la participation de chacun variant entre 1 % et 15 %. Un des employés vend ses actions à 1) un des autres employés-actionnaires, 2) un nouvel employé-actionnaire. ...
Technical Interpretation - Internal summary
15 January 2004 Internal T.I. 2003-0026827 - Non-resident & Tuition & Educations credits -- summary under Section 118.9
15 January 2004 Internal T.I. 2003-0026827- Non-resident & Tuition & Educations credits-- summary under Section 118.9 Summary Under Tax Topics- Income Tax Act- Section 118.9 no ability of child to transfer the credit where she was a non-resident with no Cdn. source of income A Canadian-resident father is claiming tuition and education tax credits transferred under s. 118.9 from his non-resident daughter who has been living with her mother in the U.S. since the couple’s divorce and has now been attending university in the U.S. ... The Directorate stated: Based on the line of reasoning in Oceanspan … and other cases … an individual who is not resident in Canada and who has no Canadian source income would not be entitled to the tuition and education tax credits. The individual is not liable to pay tax in Canada, and therefore has no need to utilize the provisions permitting the tax credits. … If the daughter was required to compute tax payable under Part I of the Act, then we agree that she would be entitled to the tuition tax credit under section 118.5 of the Act, assuming she otherwise qualified. … These credits, then, would be eligible for transfer to her father under the rules in sections 118.81 and 118.9. ...