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1 January 2025- 11:35pm CRA finds that the property of an alter ego trust “belonged” to its sole trustee and life beneficiary rather than to the trust Email this Content In order for a fee paid to a corporation for the executive producer servicers of an individual employed by the corporation to qualify for the B.C. production services tax credit, there was a requirement (essentially copied from ITA s. 125.4(1) – labour expenditure – (b)(iii) and s. 125.5(1) – Canadian labour expenditure- (b)(iii)) that the shares of the corporation “belong” to a BC-based individual – whereas, here, the shares were held by the individual in his capacity of trustee of an alter ego trust which had been settled by him (to avoid B.C. probate duties) and of which he was the life beneficiary. ... [Here] … [the individual] has legal ownership of the shares in [the individual’s] role as trustee, and beneficial ownership of the shares as the sole beneficiary who is entitled to the income on the shares while [the individual] is alive …. ... Summary of 9 July 2024 Internal T.I. 2023-0976691I7 under s. 125.4(1) – labour expenditure – (b)(iii). ...

“Standard contractual representations and indemnities with respect to the failure to deduct or withhold an amount under section 215, in an arm's length situation … “ A standard clause in a partnership agreement providing for reasonable assistance to a partner to help resolve an audit. ... Summaries of Mandatory disclosure rules – Guidance, 2 November 2023 CRA Webpage under s. 237.3(1) – reportable transaction – (a), confidential protection, contractual protection, s. 237.3(2), s. 237.4(6), s. 237.4(7), s. 237.5(1)- relevant financial statements, reportable uncertain tax treatment. ...

Summaries of S3-F2-C1 under s. 83(2), s. 89(1) – capital dividend account – para. (a), s. 89(1) – capital dividend account – para. (b), s. 89(1) – capital dividend account – para. ...

The notion that one can do so is closely related to the … Marxist … labour theory of value – an intuitive notion that has since been thoroughly debunked…. ... Summary of Kevyn Nightingale, "Private Company Income-Splitting Proposal Part 3: The Government Responds", Tax Topics (Wolters Kluwer), No. 2389-90, December 21, 2017, p. 1 under s. 120.4(1) – reasonable return – para. ...

Summary of HBC Circular under Mergers & Acquisitions – Cross-Border Acquisitions – Inbound. ...

Any secrecy must be necessary, justified and minimized …. … In the Federal Court, the submissions containing confidential information were only a small part of the hearing. ...

15 March 2022- 12:04am Loral merges pursuant to a Delaware merger with Telesat Canada through creation of new Canadian partnership/corp holding structure Email this Content Telesat Canada, a Canadian corporation and global satellite operator that was mostly owned by Loral Space & Communications Inc. ... The resulting sandwich structure entailed a non-Canadian partnership (Telesat Partnership – held by a B.C. corporation, Telesat Corporation) holding shares of a controlled foreign affiliate (Loral) which, in turn, received FAPI income in the form of Canadian-source dividends. ... Summary of 16 November Non-Offering Prospectus of Telesat Corporation and Telesat Partnership and 30 June 2021 Proxy Circular (Schedule 14A) of Loral Space &Communications Inc. under Mergers & Acquisitions – Cross-Border Acquisitions – Outbound – Delaware etc. ...

17 September 2023- 11:27pm The mandatory-disclosure rules do not comply with the constitutional requirement to place a disclosure obligation on lawyers only when “absolutely necessary” Email this Content Chambre des notaires found that a limitation imposed on solicitor-client privilege (SCP) that was “ not absolutely necessary to achieve the purposes of the ITA ” thereby infringing on s. 8 of the Charter, and further found that there it was “ not absolutely necessary … to rely on notaries or lawyers rather than on alternative sources in order to obtain the information or documents being sought.” ... Summary of Élisabeth Robichaud and Marie-Emmanuelle Vaillancourt, “An Avoidable Threat to the Protection of Solicitor-Client Privilege,” Perspectives on Tax Law & Policy, Vol. 4, No. 3, September 2023, p. 11 under s. 237.4(18). ...

10 October 2016- 10:51pm On the Agrium/PotashCorp merger, all shareholders would move to a new holdco and s. 85.1 treatment for non-electing shareholders would be busted through a 3-party exchange Email this Content In a proposed “merger of equals,” resident taxable shareholders of Agrium and PotashCorp who had validly elected for rollover treatment would transfer their shares under s. 85.1 to a Newco (“New Parent” – whose initial nominal capital would be owned on a 50-50 basis by Agrium and PotashCorp) in exchange for common shares of New Parent. ... Summary of Joint Agrium/PotashCorp Circular under Mergers & Acquisitions – Mergers – New Holdco. ...

Summary of 22 September 2017 External T.I. 2016-0668041E5 under s. 248(1) – taxable Canadian property – (d) and Treaties – Articles – Art. 13. ...