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., pre-ordained or pre-ordered transactions that can be construed as a single composite transaction)… [and] the extended meaning of series under the ITA, as set out by the SCC … should not be relevant …. ... Lennard, “Interpreting the Expression “Arrangement or Transaction” in the Principal Purpose Test of the MLI,” International Tax (Wolters Kluwer CCH), June 2019, No. 106, p. 1 under Treaties – MLI – Art. 7(1). ...

XXIV(2)(a) is expressly “subject to the provisions of the law of Canada regarding the deduction from tax payable in Canada of tax paid in a territory outside Canada,” and stated that “this means that a Canadian resident is subject to the limitations on claiming a foreign tax credit found in the Canadian legislation, and more specifically in section 126, including a timing restriction on when a foreign tax credit may be claimed (see … 2015-0601781E5 ….) ... Summaries of 3 February 2022 Internal T.I. 2021-0922301I7 under Treaties – income Tax Conventions – Art. 13, Art. 24. ...

In order that Parent could get basis for having issued the share consideration, it was stated in a funding agreement to have issued such shares in consideration for the issuance to it by Merger Sub1 of common shares of Merger Sub1 – and CRA ruled that indeed those shares issued to Parent had a cost to it equal to the FMV of the shares issued by it in turn to the Target shareholders plus any related costs incurred by it. ... CRA further ruled that on the immediately subsequent contribution by Parent of its shares of Merger Sub1 to Opco, it did not realize gain, and Opco had full cost for those shares pursuant to s. 53(1)(c) – and Opco also was able to increase the PUC of its shares in reliance on s. 84(1)(b) in an amount equal to the FMV of those contributed shares. ... Summaries of 2021 Ruling 2021-0911211R3 under s. 54 – ACB, s. 248(1) – disposition – (k)(ii), s. 84(1)(c) and General Concepts – Payment and Receipt. ...

In finding that the tax solicitor was negligent in failing to warn of this specific risk, Asplin LJ stated: [I]t is perfectly possible to be correct about the construction of a provision or, at least, not negligent in that regard, but nevertheless to be under a duty to point out the risks involved and to have been negligent in not having done so …. …There was a significant risk that the … advice was wrong and in all the circumstances, a reasonably competent solicitor would have gone beyond his own view and set out the risks. ... Summary of Barker v Baxendale Walker Solicitors (a firm) & Anor, [2017] EWCA Civ 2056 under General Concepts – Negligence and Statutory Interpretation – Interpretation Act – s. 10. ...

11 June 2020- 12:12am CRA applies a functional approach to determining the ownership of the “capital” of a non-share corporation Email this Content In response to an inquiry on the Crown corporation branch of the definition of a public institution in s. 125.7(1) of the CEWS rules, CRA first paraphrased the rules in ss. 149(1)(d) to (d.6) as well as referring to the deeming rule in s. 149(1.1), and then indicated that, in determining the ownership of the “capital” of a non-share corporation for these purposes, it would consider the following factors: • the identity of members, • the structure of the corporation, • who exercises control over the financing, operation and direction of the corporation, • who has the right to elect or change the board of directors or to reverse its decision, • who can contribute capital and receive a distribution of capital, • details regarding asset distribution on winding-up or dissolution and • whether a person other than her Majesty in right of Canada, a province or a Canadian municipality has any right to acquire any capital of the corporation. ... Summary of 1 May 2020 External T.I. 2020-0846931E5 under s. 125.7(1) – public institution- (a). ...

. … [Y]ou have advised … that … there is no change in the capital structure of the Corporation, the number of outstanding shares, the number of shares held by any shareholder, or the interest, rights, or privileges attached to any share. [Accordingly] …. the actions undertaken would not, in and of themselves, constitute a redemption, acquisition, or cancellation of any share of the Corporation, or otherwise result in a disposition of a share of the Corporation. ... Summary of 28 June 2022 External T.I. 2022-0933661E5 under s. 248(1) – disposition. ...

S. 4.1 of the ITCIA provides that “notwithstanding the provisions of a Convention … the GAAR, applies to any benefit provided under the Convention.” ... Summaries of 14 May 2019 IFA Conference – Stephanie Smith on MLI – GAAR and PPT under Treaties – MLI – Art. 7(1), Art. 19 and Art. 4. ...

Summary of 11 October 2019 APFF Financial Strategies and Instruments Roundtable, Q.2 under s. 146.01(1) – regular eligible amount – (f) and s. 118.05(1) – qualifying home – (a). ...

25 October 2022- 10:48pm CRA indicates that a corporation cannot change its year end by objecting to the 1st year’s initial assessment Email this Content 2020-0874951I7 indicated that if a request for a retroactive change to a taxation year is made after the corporate tax returns are filed but before the first Notice of Assessment for that year is issued, it will generally be granted – but not if such request is made after such issuance. ... In rejecting this approach, CRA stated: For the purposes of subsection 165(3), an assessment may generally be vacated upon receipt of a Notice of Objection if a taxpayer submits additional facts or compelling arguments that were not before the Minister at the time the assessment was made and that demonstrate that the assessment is either invalid … or was unfounded …. [Here] … the mere fact that the corporation wishes to change the timing of its fiscal period end after tax has been assessed for the year corresponding to the fiscal period, even if it is the corporation's first fiscal period, does not, in and of itself, invalidate or render unfounded the [initial] assessment …. ...

Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.8 under s.129(4) – NERDTOH – (a)(i). ...