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Summary of 21 October 2024 External T.I. 2024-1027501E5 under Reg. 1100(2)(A), s. 127(9) – government assistance and s. 13(1). ...

These are additions to our set of 3,017 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ½ years of releases of such items by the Directorate. ...

Summary of 3 December 2024 CTF Roundtable, Q.14 under s. 129(4) – “income” or “loss”. ...

These are additions to our set of 3,053 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 23 ¾ years of releases of such items by the Directorate. ...

Langlois, which found that a 50% shareholder who had “an operational role, not a decision-making role” was not part of the de facto control of the corporation, whereas the other shareholder, who “[a]s the sole director … had the power that ensured him a dominant influence in the direction of the [corporation]” had de facto control. ...

Summary of Joint Committee, Federal Budget 2024 – Capital Gains Inclusion Rate, 22 January 2025 Joint Committee submission under s. 38(a). ...

In finding that s. 152(4)(b)(vii) did not authorize CRA to reassess the trust within three years of the expiry of the normal reassessment period to adjust the proceeds of disposition, the Directorate indicated: The relevant scoping condition in s. 152(4)(b)(vii) – that the assessment was “to give effect to the application of section 94”- meant “to cause section 94 to apply.” ...

These are additions to our set of 3,123 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 ¼ years of releases of such items by the Directorate. ...

Summary of May 1, 2025 Circular of Maple Leaf Foods Inc. under Spin-offs and Distributions – Butterfly spin-offs. ...

The two deferred payments were not made on the agreed dates because of disagreements about the method for their computation. 21 months after the closing date, the parties agreed that a deferred payment of $50,000, rather than $200,000 + $300,000, would be paid. ...