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Summaries of Joint Committee, “Subject: Proposed Part II.2 Tax – Tax on Repurchases of Equity – ‘Reorganization Transaction,’ 26 March 2024 Joint Committee Submission under s. 183.3(1) – reorganization – (b), (c), s. 183.3(2), s. 183.3(2) – B. ...

After indicating that “one could argue that the Developer holds legal ownership for the benefit of the Builder and is required to transfer legal ownership … to any third party at the Builder’s request (for example, to the Home Buyer …)” CRA stated: [P]rovided that legal ownership is transferred from the Developer, at the Builder’s direction at Subsequent Closing, to the Home Buyer who is the particular individual with whom the Builder has entered into the Home Buyer Agreement, the CRA will … regard the Builder as having transferred ownership of the House or Unit … to the Home Buyer …. Therefore … provided that all of the other conditions … are met, the Builder may pay or credit the Rebate to the Home Buyer. ...

Summaries of Joint Committee, “Guidance on International Income Tax Issues raised by the COVID-19,” 11 June 2020 Joint Committee Submission under Reg. 5907(1) – exempt earnings – (d). s. 95(1) – FAPI, Treaties – Income Tax Conventions – Art. 5, s. 153(6). ...

Rye / Klein line of cases): It is well established at common law that a man cannot contract with himself and that a partner cannot contract with a partnership of which he is a member. ... Act: “A limited partner may loan money to and transact other business with the limited partnership … ” (i.e., s. 12 does not specifically refer to limited partner borrowings). ... Summary of 16 December 2019 Internal T.I. 2019-0816101I7 under s. 96(2.2)(c) and Statutory Interpretation – Interpretation Act, s. 8.1. ...

. … [T]he word “misrepresentation” in English, alone, encapsulates the concept of a false, misleading, wrong or incorrect representation in relation to facts. … … Because the filing position of a taxpayer involves the disclosing, reporting or characterization of the taxpayer’s underlying factual situation, any false, misleading, incorrect or incomplete disclosure, reporting, or characterization of those facts could constitute a misrepresentation [of the facts]. … [A] reasonable filing position would be one where, upon review of all of the facts and circumstances that underlie a taxpayer’s situation (fully and accurately addressed), the Minister and the taxpayer could arrive at reasonable—albeit different—conclusions or positions based on a characterization of (or an application of the law to) such facts. ...

Whether dividends on her shares qualified for the excluded amount exception turned on whether the Opco business was an excluded business on the basis that she was “actively engaged on a regular, continuous and substantial basis in the activities of the [Opco] business … in … any five prior taxation years.” In finding that her having put in her 5-year stint many years ago while an arm’s length employee was no barrier to meeting this test, CRA stated: [T]here is no requirement that the prior taxation years where the specified individual is actively engaged on a regular, continuous and substantial basis must be consecutive, nor is there a requirement that the specified individual must be related to the particular source individual at the time such qualifying activities are performed. … [and] these years can be before the effective date of the amendments to section 120.4. ... Summary of 27 February 2019 External T.I. 2018-0783741E5 under s. 120.4(1) – excluded business – para. ...

Summary of 16 December 2016 Interpretation 169841 under ETA – s. 123(1) – financial service – (l). ...

With respect to the expression “in any manner whatever’ in subsection 84(2), the Court noted that “ [t]hese far-reaching words are anchored in history as they have always been part of this provision, and they faithfully reflect its anti-avoidance purpose”. ... [Foix] also resolved the uncertainties arising from certain decisions that taxpayers frequently invoked against the application of subsection 84(2), namely, McNichol … Descarries … and Robillard … [and] warn[ed] against the formalistic and restrictive application of subsection 84(2) put forward in those decisions. CRA also indicated that “ Foix did not express an opinion on the Tax Court of Canada's analysis in Geransky ” and implied that Geransky has been overtaken by the subsequent decisions of the Federal Court of Appeal in MacDonald and Foix, which “clearly ruled that subsection 84(2) should be given a broad interpretation.” ...

Summary of Tahoe Resources Circular under Mergers & Acquisitions – Mergers – Shares for CVRs, and Shares or Cash. ...

It added: [T]he CRA took a similar approach in … 2016-0628181R3 by adding an opinion that any dividend … paid … on the shares of … the private corporation (Holdco) to the foundation (Foundation), which had previously acquired the shares as a result of the transfer of the shares by the testamentary spousal trust for the spouse of the deceased following the death of the spouse, would be considered not to be a taxable dividend, with the result that subsection 129(1. 2) would apply …. ...