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Technical Interpretation - External summary
15 December 2006 External T.I. 2006-0182471E5 F - Intérêts " explicitement identifiés " -- summary under Paragraph 12(1)(c)
15 December 2006 External T.I. 2006-0182471E5 F- Intérêts " explicitement identifiés "-- summary under Paragraph 12(1)(c) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(c) whether a court order or settlement “explicitly identifies” pre-judgment interest, so as to be taxable, is question of fact Regarding requested clarification of the position in Income Tax Technical News No. 30 that all pre-judgment interest, which is “explicitly identified” as interest in a court order or out-of-court settlement, will be taxed as interest income, CRA stated: [T]he tax treatment of pre-judgment interest explicitly identified as described in your request varies according to the specific terms and conditions of each judgment or out-of-court settlement. ...
Decision summary
Hill & Anor. v. C. & E. Cmners., [1988] BTC 5139 (QBD) -- summary under Agency
Hill & Anor. v. C. & E. Cmners., [1988] BTC 5139 (QBD)-- summary under Agency Summary Under Tax Topics- General Concepts- Agency A commercial gallery successfully argued that it was selling pottery as agent for some potters, rather than as principal. ...
SCC
Tees & Persse Ltd. v. The King / Watt & Scott (Toronto) Ltd. v. The King / Weddel Limited v. The King, [1946] SCR 499
Tees & Persse Ltd. v. The King / Watt & Scott (Toronto) Ltd. v. ... The King / Watt & Scott (Toronto) Ltd. v. The King / Weddel Limited v. ... For the purpose of the levying of any duty, * * * (a) The importation of any goods * * * shall be deemed to have been completed from the time such goods were brought within the limits of Canada, * * * Section 35 commences "whenever any duty ad valorem is imposed on any goods imported into Canada ". ...
Technical Interpretation - Internal summary
7 May 1995 Internal T.I. 9510220 - PART I.3, O/S CHEQUES & OVERDRAFTS -- summary under Payment & Receipt
7 May 1995 Internal T.I. 9510220- PART I.3, O/S CHEQUES & OVERDRAFTS-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt conditional payment principle accepted Bank overdrafts are considered to have arisen to the extent that they have been utilized or drawn upon. ...
Conference summary
16 June 2014 STEP Roundtable, 2014-0526591C6 - STEP CRA Roundtable June 2014 Question 9 -- summary under Subsection 156(1)
16 June 2014 STEP Roundtable, 2014-0526591C6- STEP CRA Roundtable June 2014 Question 9-- summary under Subsection 156(1) Summary Under Tax Topics- Income Tax Act- Section 156- Subsection 156(1) relief for interest and penalties on deficient inter vivos trust instalments Does CRA assess instalment interest and penalties where an inter vivos trust has not made instalment payments required under s. 156? ...
Decision summary
Clyde & Co LLP & Anor v Bates Van Winkelhof , [2012] EWCA Civ 1207 -- summary under Section 96
Clyde & Co LLP & Anor v Bates Van Winkelhof, [2012] EWCA Civ 1207-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 partner in partnership cannot be an employee The claimant, who was a solicitor practising as an equity member of a limited liability partnership, and who was expelled as a member, was found not to be a "worker" entitled to protection under the Employment Rights Act 2010 (UK). ...
News of Note post
10 April 2021- 11:41pm CRA is now applying a “proportionate attribution approach” in applying the EIA s. 5(2)(b) test of “control … of … voting shares” Email this Content S. 5(2)(b) of the Employment Insurance Act provides that “Insurable employment does not include … the employment of a person by a corporation if the person controls more than 40% of the voting shares of the corporation.” ... In stating that it accepted Boifor, so that its previous position was reversed, CRA addressed the example of two 50-50 (or 51-49) shareholders of a Holdco wholly owning their employer (Opco), and stated: In light of the FCA's decision, the CRA must now consider the proportionate attribution approach in similar situations to determine whether the employment of a person who controls more than 40% of the voting shares of the employing corporation is insurable. … … The proportionate attribution approach leads to the conclusion that the two shareholders each control more than 40% of Opco's voting shares (50% of 100%) for the purposes of EIA paragraph 5(2)(b). … … [W]here the shareholders held 51% and 49% of the voting shares of Holdco … their employment [also] would not be insurable because they had effective control of 51% and 49% of the voting shares of Opco …. ...
Decision summary
Goldcorp Exchange Ltd & Ors v. Leggett & Ors, [1994] UKPC 3, [1995] 1 AC 74 -- summary under Ownership
Goldcorp Exchange Ltd & Ors v. Leggett & Ors, [1994] UKPC 3, [1995] 1 AC 74-- summary under Ownership Summary Under Tax Topics- General Concepts- Ownership no ownership of unascertained goods At the time banks appointed receivers for a dealer in precious metals, the dealer had a stock of precious metal bullion that was substantially less than that which was required to satisfy contracts of the public for purchases of precious metals for future delivery. ...
Article Summary
Allan Lanthier, "Tax relief for family business transfers: A legislative fiasco – Part I / Tax relief for family business transfers: A legislative fiasco – Part II", Canadian Accountant, 8 July 2021 (Part I) and 9 July 2021 (Part II) -- summary under Paragraph 84.1(2)(e)
Allan Lanthier, "Tax relief for family business transfers: A legislative fiasco – Part I / Tax relief for family business transfers: A legislative fiasco – Part II", Canadian Accountant, 8 July 2021 (Part I) and 9 July 2021 (Part II)-- summary under Paragraph 84.1(2)(e) Summary Under Tax Topics- Income Tax Act- Section 84.1- Subsection 84.1(2)- Paragraph 84.1(2)(e) Overview Bill C-208 generally provides that an individual selling qualified small business shares or shares of a family farm or fishing corporation to a corporation controlled by the individual’s children or grandchildren who are at least 18 years of age will benefit from capital gains treatment rather than a s. 84.1 deemed dividend provided that such purchaser does not dispose of those shares for at least 60 months. ... Example of strip Emily transfers her shares of a small business corporation (Petco) with nominal tax basis and paid-up capital to a Newco- in which her daughter owns nominal value special voting shares giving her voting control, and Emily owns the balance of the equity – in consideration for a promissory note, which is repaid over the next five years with intercorporate dividends received by Newco from Petco. ... Furthermore, the math in the formula is wrong – even if it were effective, it would only eliminate the deduction at taxable capital levels of $510 million, not $15 million. ...