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News of Note post
6 June 2021- 10:34pm Brent Carlson Family Trust – Federal Court finds that CRA had been confused by the rectification jurisprudence in rejecting an amended s. 85(1) election Email this Content In implementing a plan to maximize the utilization by family members of the capital gains exemption (“CGE”) on the sale to an arm’s length purchaser of an operating company that was indirectly held by family trusts, the trusts engaged in a dirty s. 85(1) exchange of existing low-basis common shares of a subsidiary for new shares of that subsidiary that included Class F preferred shares, with a joint s. 85 election being filed at an agreed amount that resulted in recognition of a capital gain equaling the aggregate CGE available to the trust’s beneficiaries. ... Before setting aside and remitted to the Minister for redetermination, Walker J stated: … The Minister’s delegate … imports equitable requirements specific to rectification and rescission without acknowledging any difference in the remedies sought. … They requested only the amendment of the Original Elections, as contemplated in subsection 85(7.1). ...
Old website (cra-arc.gc.ca)
Online mail – Reduce your cost of doing business by saving time – go online
Online mail – Reduce your cost of doing business by saving time – go online Video: Manage online mail for businesses Video: Manage online mail for businesses Transcript Online mail is a simple to use service that allows businesses to receive most of their mail, like their notice of assessment or statements, from the Canada Revenue Agency (CRA) directly in My Business Account. ... How to register for online mail Signing up is easy – here are three ways you can register to receive online mail from the CRA: log in to My Business Account and select “Manage online mail” if you are an authorized representative, register or log in to Represent a Client to access My Business Account provide your email address when using the Corporation Internet Filing service and GST/HST NETFILE service When registering, you should provide the email address or addresses of account(s) that are regularly used. ... Correspondence that you can receive electronically Some examples of correspondence currently available through online mail include: notices of assessment (NOA) notices of reassessment (NORA) PD7A – statement of account for current source deductions statements letters The CRA continues to add more correspondence to our online mail service every year. ...
23 June 2016- 11:17pm Kruger – Federal Court of Appeal finds that non-statutory mark-to-market accounting was permissible under s. 9, and that derivatives not held for resale are not inventory Email this Content Kruger engaged in extensive trading of FX options, mostly writing European style puts and calls, although it also purchased FX options. ... The Queen, 2016 FCA 186 under s. 9 – timing, s. 248(1) – inventory. ...
News of Note post
25 September 2020- 12:07am Godcharles – Court of Quebec finds that a sale of goodwill occurred between parties acting in concert given the role of a dominant player Email this Content A retirement home was co-owned by eight individuals and operated by a corporation of which they were the shareholders. ... Agence du revenu du Québec, 2020 QCCQ 2219 under s. 251(1)(c) and General Concepts – fair market value – real estate. ...
Current CRA website
T2 Corporation – Income Tax Guide – Before you start
T2 Corporation – Income Tax Guide – Before you start From: Canada Revenue Agency On this page... ... If you have questions about non‑resident returns, go to Businesses – International and non-resident taxes. ... For more information, see IT393R2 – Election Re: Tax on Rents and Timber Royalties Non-Residents. ...
News of Note post
Matco then identified a mutual fund management company which wanted to effect a public offering of shares of the taxpayer and use the proceeds (of $100M) for a new bond trading business to be carried on in the taxpayer – a transaction which then proceeded. ... In finding that the transactions (which he described, at para. 6, as “narrowly circumventing the text of s. 111(5)”) did not accord with the rationale of s. 111(5), so that the use of the tax attributes had been properly denied under s. 245(2), Rowe J stated: [T]he appellant was gutted of any vestiges from its prior corporate “life” and became an empty vessel with Tax Attributes. … Moreover, the shareholder base of the taxpayer underwent a fundamental shift throughout the transactions …. Matco achieved the functional equivalent of … an acquisition of [de jure] control through the Investment Agreement, while circumventing s. 111(5), because it used separate transactions to dismember the rights and benefits that would normally flow from being a controlling shareholder. ...
Article Summary
Charles P. Marquette, "Hybrid Sale of Shares and Assets of a Business", Canadian Tax Journal, (2014) 62:3, 857 – 79. -- summary under Subsection 84(2)
Marquette, "Hybrid Sale of Shares and Assets of a Business", Canadian Tax Journal, (2014) 62:3, 857 – 79.-- summary under Subsection 84(2) Summary Under Tax Topics- Income Tax Act- Section 84- Subsection 84(2) Description of hybrid transaction using external step-up in basis method (pp. 878-9) [T[he hybrid form of transaction for a corporate business sale utilizes both traditional elements of a business acquisition – the purchase of shares and assets – in order to limit the ultimate tax liability incurred by the vendor and to maximize the cost base of assets for the purchaser…. ... [fn 22: … 2003-0029955 … See also Geransky v. The Queen, 2001 DTC 243…] The CRA has confirmed that in such a situation, subsection 84(2) or 245(2) would not normally apply provided that (1) the vendors and the purchaser deal at arm's length, (2) the vendor shareholders receive a cash amount from the purchaser's own funds in return for shares of the target, and (3) the target's assets continue to be used in an active business by the target, or by another entity within the purchaser's corporate group. [fn 23: … 2003-0029955 …] ...
News of Note post
3 July 2018- 12:51am MacDonald – Federal Court of Appeal effectively affirms George Weston, and finds that the existence of a hedge does not turn on intention Email this Content An individual with a significant long-term holding in common shares of a public company (BNS) entered into a cash-settled forward which had the effect of establishing a short position against a portion of his BNS shareholding. ... He was aware of the hedging effect which the Forward Contract would have on the BNS shares …. ... MacD onald, 2018 FCA 128 under s. 9 – capital gain v. income – futures/forwards/hedges. ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Before you start
T2 Corporation – Income Tax Guide – Before you start On this page... ... Resident corporations All corporations — including non-profit organizations, tax-exempt corporations, and inactive corporations — have to file a T2 return for every tax year, even if there is no tax payable. ... For more information, see IT393R2 – Election Re: Tax on Rents and Timber Royalties Non-Residents. ...
Scraped CRA Website
T2 Corporation – Income Tax Guide – Before you start
T2 Corporation – Income Tax Guide – Before you start On this page... ... Resident corporations All corporations — including non-profit organizations, tax-exempt corporations, and inactive corporations — have to file a T2 return for every tax year, even if there is no tax payable. ... For more information, see IT393R2 – Election Re: Tax on Rents and Timber Royalties Non-Residents. ...