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News of Note post
3 June 2020- 12:09am Ferme Lunick – Court of Quebec finds that a farm with a substantial potato-bagging operation carried on a single farming business Email this Content The taxpayer operated a four-employee 1500-acre farm that produced potatoes, grains, market garden and dairy products, as well as a 10+-employee processing operation housed in four buildings on the farm, that purchased, sorted, washed and bagged potatoes before their sale. ... Agence du revenu du Québec, 2020 QCCQ 1703 under s. 125.1(3) – manufacturing or processing – (a). ...
News of Note post
20 February 2023- 11:58pm Ahamed TFSA – Tax Court of Canada finds that a TFSA is not exempted on profits of a business of trading in qualified investments Email this Content The self-directed TFSA of a professional investment advisor, which actively traded qualified investments (mostly, penny stocks listed on the TSX Venture Exchange), was assessed under s. 146.2(6) for its 2009 to 2012 taxation years (during which $15,000 in contributions grew to $564,483) on the basis that its net gains were income from carrying on a business. ... In dismissing the TFSA’s appeal, Spiro J stated: So long as the business is one that may be “carried on” (i.e., not an “adventure in the nature of trade”) all businesses — without statutory exception — fall within the scope of subsection 146.2(6) of the Act, including a business of trading qualified investments. ...
News of Note post
26 June 2024- 11:11pm PepsiCo – Full Federal Court of Australia finds that concentrate purchases by an Australian soft drink bottler could not be recharacterized as trademark royalties for withholding tax purposes Email this Content A U.S. company (PepsiCo) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company (the “Bottler”). ... Summaries of PepsiCo, Inc v Commissioner of Taxation [2024] FCAFC 86 under Treaties – Income Tax Conventions – Art. 12. ...
News of Note post
This occurred – the offer of another public company (Inco – the 25% minority shareholder) was accepted by the Diamond Fields shareholders, thereby triggering the payment by Diamond Fields of the break fee. ... The break fee did not qualify as proceeds of disposition of a Falconbridge right to merge, as she did not consider there to be such a right: Diamond Fields could not promise the acceptance by its shareholders of the Falconbridge offer nor could it fetter the fiduciary obligations of its board – there was no capital gain. ... Canada, 2024 FCA 3 under s. 9 – compensation payments, s. 248(1) – property and s. 12(1)(x). ...
News of Note post
“Purpose is ascertained objectively …. [T]he primary source of ascertaining a derivative contract’s purpose is the linkage between the derivative contract and any underlying asset, liability or transaction purportedly hedged.” ... MacDonald did not sell his … shares immediately to offset his losses under the forward contract does not sever this connection”. ... Canada, 2020 SCC 6 under s. 9 – Capital gain v. profit – Futures/Forwards/Hedges and General Concepts – Purpose/Intention. ...
News of Note post
12 December 2016- 12:24am Fairmont/Jean Coutu – Supreme Court of Canada appears to find that rectification to fix tax problems is limited to fixing badly implemented tax plans rather than fixing bad plans Email this Content In reversing Juliar, Brown J indicated in Fairmont that rectification only “allows a court to achieve correspondence between the parties’ agreement and the substance of a legal instrument intended to record that agreement, when there is a discrepancy between the two,” whereas in Juliar, the substance of the agreement was for the exchange of shares for a promissory note rather than shares, so that the purported rectification there was of the agreement itself rather than in the instrument recording the parties’ agreement. ... Fairmont Hotels Inc., 2016 SCC 56 under General Concepts – Rectification and Statutory Interpretation – Interpretation Act, s. 8.1; summaries of Jean Coutu Group (PJC) Inc. v. Canada (A.G.), 2016 SCC 55 under General Concepts – Rectification and Statutory Interpretation – Interpretation Act, s. 8.1. ...
Folio
S3-F10-C1 - Qualified Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs
These rules are discussed in Income Tax Folio S3-F10-C2, Prohibited Investments – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs and Income Tax Folio S3-F10-C3, Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs. ... See ¶ 1.83 and ¶ 1.86 for more details. Annuity contracts 1.47 Several types of annuity contracts are qualified investments, although some are eligible only for certain registered plans. ... Specific statutory or regulatory authority for each type of qualified investment Chapter reference Type of qualified investment (QI) Statutory or regulatory authority ¶ 1.12 money, Canadian or foreign-denominated paragraph (a) of the QI definition in section 204 ¶ 1.13 deposit with bank or trust company paragraph (a) of the QI definition in section 204 ¶ 1.14 deposit with credit union Regulation 4900(1)(g) ¶ 1.16 listed security paragraph (d) of the QI definition in section 204 ¶ 1.22 American Depository Receipt Regulation 4900(1)(w) ¶ 1.23 share of public corporation Regulation 4900(1)(b) ¶ 1.23 debt of public corporation Regulation 4900(1)(c.1) ¶ 1.25 unit of mutual fund trust Regulation 4900(1)(d) ¶ 1.26 share of mutual fund corporation Regulation 4900(1)(b) ¶ 1.27 share or unit of registered investment Regulation 4900(1)(a) ¶ 1.29 share of mortgage investment corporation Regulation 4900(1)(c) ¶ 1.30(a) debt of Government of Canada paragraph (b) of the QI definition in section 204 ¶ 1.30(b) debt of province, municipality or Crown corporation paragraph (b) of the QI definition in section 204 ¶ 1.30(c) debt of Canadian-listed corporation, mutual fund trust or limited partnership paragraph (c) of the QI definition in section 204 ¶ 1.30(d) debt of foreign-listed corporation paragraph (c) of the QI definition in section 204 ¶ 1.30(f) bankers' acceptance Regulation 4900(1)(i.2) ¶ 1.30(g) debt of authorized foreign bank paragraph (c) of the QI definition in section 204 ¶ 1.30(h) investment grade debt paragraph (c.1) of the QI definition in section 204 ¶ 1.30(i) mortgage-backed security Regulation 4900(1)(j.2) ¶ 1.33 arm’s-length mortgage Regulation 4900(1)(j) ¶ 1.36 non-arm’s-length mortgage Regulation 4900(1)(j.1) ¶ 1.38 unlisted warrants and options Regulation 4900(1)(e) ¶ 1.48 segregated fund annuity contracts paragraph (c.1) of the QI definition in subsection 146(1), paragraph (c) of the QI definition in subsection 146.1(1), paragraph (b.1) of the QI definition in subsection 146.3(1), paragraph (b) of the QI definitions in subsections 146.4(1) and 207.01(1) ¶ 1.49 RRSP annuity paragraph (c) of the QI definition in subsection 146(1) ¶ 1.50 qualified annuity paragraph (c.2) of the QI definition in subsection 146(1), paragraph (b.2) of the QI definition in subsection 146.3(1) and paragraph (c) of the QI definition in subsection 146.4(1) ¶ 1.51 gold and silver coins, bullion and certificates Regulation 4900(1)(t), (u) and (v) ¶ 1.55 small business investments Regulation 4900(6) and (14) Application This updated Chapter, which may be referenced as S3-F10-C1, is effective May 28, 2024. ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Chapter 6: Pages 6 and 7 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 6: Pages 6 and 7 of the T2 return On this page... ... For information on Part IV tax and instructions to complete Schedule 3, see line 712 – Part IV tax payable. ... The dividend refund is equal to whichever of the following amounts is less: 1/3 of taxable dividends that you paid in the year while a private or subject corporation; or For tax years that end after 2015, the 1/3 rate (= 33 1/3%) is increased to 38 1/3%. ...
Scraped CRA Website
T2 Corporation – Income Tax Guide – Chapter 6: Pages 6 and 7 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 6: Pages 6 and 7 of the T2 return On this page... ... For information on Part IV tax and instructions to complete Schedule 3, see line 712 – Part IV tax payable. ... The dividend refund is equal to whichever of the following amounts is less: 1/3 of taxable dividends that you paid in the year while a private or subject corporation; or For tax years that end after 2015, the 1/3 rate (= 33 1/3%) is increased to 38 1/3%. ...
Current CRA website
T2 Corporation – Income Tax Guide – Chapter 6: Pages 6 and 7 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 6: Pages 6 and 7 of the T2 return From: Canada Revenue Agency On this page... ... For more information on eligible dividends, go to Eligible dividends or Line 710 – Part III.1 tax payable. ... For information on Part IV tax and instructions to complete Schedule 3, Dividends Received, Taxable Dividends Paid, and Part IV Tax Calculations, see line 712 – Part IV tax payable. ...