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Canada has particular challenges going down the corporate route – only 10% of Canadian corporations are registered federally, and the rest are distributed among the provinces and territories. ... We are still working through all the design issues – I think this group can appreciate the kind of gyrations we’re going through in trying to develop an appropriate measure dealing with passive investment income – so we are still working on those key design elements and we will be looking at all the planning deferral benefits that arise with respect to passive investment income. ...

From 1978 on, this lead to all sorts of preferred share rules – the term preferred share rules, the guaranteed and short-term preferred share rules, collateralized preferred shared rules, leading all the way up through that decade, to the taxable preferred share rules in 1987. ... There was this view that we were legislating by press-release – every fortnight, we were dealing with something else. ... Reading the Wild case, it seems inconsistent with the expressed intention of Parliament – but I also appreciate the legislative concern that the decision identified. ...

That subclause provides that, if a particular foreign affiliate of a taxpayer provides services to another foreign affiliate of the taxpayer, then, to the extent that amounts paid by the other foreign affiliate in consideration for the services are deductible in computing its foreign accrual property income ("FAPI") (as defined in subsection 95(1) of the Act), these amounts are deemed to be income of the particular foreign affiliate from a business other than an active business – and are therefore included in the particular foreign affiliate's FAPI. ... Yours sincerely, Brian Emewein General Director – Legislation Tax Policy Branch ...

The February 4, 2022 draft legislative proposals regarding s. 160 planning; audit authority and enhanced trust reporting; as well as the interest measure: Finance is working through the comments – see also below. ... McGowan: All of the following examples are subject to solicitor-client privilege – reporting would not be required where it would breach privilege. ... There is limited flexibility to deviate from the Model Rules – we do not know yet precisely how much latitude we have, and we hope for further guidance soon. ...

Pillars 1 and 2 process International tax has been a key priority in recent years – including the “Pillars project.” ... Detailed blueprints were released and consulted on a year ago in October, but these did not necessarily reflect an agreed path forward, especially on Pillar 1 – which the previous US administration was not prepared to sign on to. ... Pillar 1 is quite novel, essentially adopting a formula allocation for a subset of profits of large MNE groups determined using accounting values – at least three sources of novelty. ...

For more information concerning the completion of NR4 information slips, please consult Guide T4061, NR4 – Non-Resident Tax Withholding, Remitting and Reporting. ... However, as a matter of practice, all APAs entered into by the CRA include a series of critical assumptions – that, if breached, may require that the terms of the APA be re-visited. ... That is not to say that certain allowances (for example – the use of limits / critical assumptions to collar or point to a specific return within a range) will not be required for certain taxation years over a proposed APA term; however, when and how this is implemented will be addressed on a case-by-case basis. ...

The word “ control” might conceivably refer to de facto control by "one or more shareholders whether or not they hold a majority of shares. | am of the view, "however, that in section 39 of the Income Tax Act, the word “controlled” contemplates the right "of control that rests in ownership of such a number of shares as carries with it the right to a "majority of the votes in the election of the Board of Directors. ... C., at page 15, says: " ">The owners of the majority of the voting power in a company are the persons who are in ">effective control of its affairs and fortunes. ... Therefore, the rental income earned on real or immovable property in Canada would be included in the computation of a deemed resident trust’s income under Part |. ...

We think that is a reasonable approach – although not applying black-letter law, we believe that there is room for fairness in tax administration. ... Under the chain rules, if the Brazilian affiliate had a chain of other foreign affiliates under it, that could also by reason of the chain rules result in the denial of FAT in respect of FAPI for those underlying subsidiaries – or any subs up above, as well. ... Response Dave Beaulne: A point of clarification – it’s not about amounts described under in Part XIII, but about amounts described in Reg. 202(1). ...

Canco pays a dividend (the “ Dividend”) to the trust which is then distributed by the trust to the Specified Individual. ... In the example provided, there are no facts which suggest that the Estate was required to file a return of income under Part | before the 2018 taxation year. ... Whether or not a liability for alternative minimum tax could arise (if the income is removed from the trust by way of deduction at line 471 of the T3 Return) The treatment of income where subsection 75(2) applies was considered in the case of Fiducie Financiere Satoma v Canada (“ Satoma ”; 2018 DTC 5052, Federal Court of Appeal “FCA”). ...

And now that we have had these BEPS announcements, and the G20 noticing the OECD last fall, and our budget announcement earlier this year, I have felt the contrarian in saying: Look, those are just the promises – there is a lot of the heavy work to do. ... Peer review There also is the BEPS “implementation framework,” which is a sort of peer review exercise whereby we will be assessing other countries, and other countries will be assessing us, on how we are doing in implementing the BEPS matters – or, at least, the minimum standards and other international standards. ... We have had an example of that in the past – Canada did that with the US. ...