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Conservation des renseignements La politique relative à la conservation des documents obtenus lors de vérifications et d'autres renseignements connexes varie selon le type de vérification et de contribuable / inscrit concerné. ...

Response prepared by Ryan Bousquet Industry Specialist Services – Insurance International, Large Business and Investigations Branch Sylvie Danis 2018-075297 May 8, 2018 ENDNOTES 1 2013 TCC 174. ...

Du point de vue de la politique fiscale lors de la constitution de Nouco, la société mère, M Ltée, agissait déjà en tant qu'’" âme dirigeante " de Nouco. ...

Tax Executive Institute 1999 Section 23 file # 1999-000672 Question XXVI: Scope of Proposed Subsection 6(23) There is substantial ambiguity about the scope of proposed subsection 6(23) and the various types of relocation expenses paid or reimbursed by the employer. ...

As stated in Archived Income Tax Technical News # 33, the CRA believes that these three conditions form an appropriate framework for a PE analysis and any relevant factor to a PE determination has to revolve around one of these three conditions. ...

Reasons: The CRA does not intend to generally substitute its judgement of what would be considered a reasonable amount where taxpayers have made a good faith attempt to do so based on the reasonableness factors. 2021 STEP CRA Roundtable – June 15, 2021 QUESTION 3. ...

It is also consistent with the other paragraphs which, although not using the word “goods”, refer to: (c) the transmission of electronic signals or electricity along a transmission system located outside Canada; or (d) the manufacturing or processing outside Canada […] of tangible property, or for civil law corporeal property” [emphasis added] If no other exclusions are met, 95(2)(b) would apply to services provided in connection with the sale of real estate inventory, including residential condominiums. ...

Reasons: Plain meaning of words, as well as various TCC and FCA positions and OECD Model Convention Commentary. 2022 International Fiscal Association Conference CRA Roundtable Question 1- Meaning of Habitual Abode in Canadian Tax Treaties As you know, Canada’s extensive treaty network contains residency “tie-breaker” provisions – usually in Article IV:2 of most of the treaties. ...

First, because of the special deferred treatment given to pre-acquisition surplus dividends paid on foreign affiliate shares held by a partnership (as per subsections 92(4) to (6) of the Act), this new election is not available where any electing corporation (as described in subparagraph 5901(2)(b)(i)), or a foreign affiliate of such a corporation, is a member of a partnership and that partnership is a shareholder of the dividend-paying foreign affiliate. […]” We would not reach the same conclusion if the Assumed Facts were changed such that FA only had one class of shares issued and outstanding, and LP owned a portion of those shares and received a portion of the dividend paid by FA. ...

The aggregate of all such loans received by the limited partner in respect of a partnership’s fiscal period does not exceed the total of the “ limited partner’s share of the partnership adjusted net income” (footnote 2) for such period and the limited partner’s adjusted cost base (“ACB”) at the end of the fiscal period (ACB determined before the application of subparagraph 53(2)(c)(v) to the loans); or if there is an excess, the excess is an immaterial amount. 3. ...