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Sierra Metals is relying on a preliminary internal sale to qualify its capital distribution of a subsidiary under s. 84(4.1)

Summary of preliminary prospectus of Cautivo Mining under Spin-Offs & Distributions – Ss. 84(4.1)(a) and (b) distributions of proceeds. ...

CRA extends the effective date for applying advantage tax, where RRSP or TFSA fees are paid by the annuitant or holder, to 2019

Summary of 15 September 2017 External T.I. 2017-0722391E5 under s. 207.01(1) – advantage – (b)(i). ...

The proposed ETA s. 272.1(8) is not a general partner distribution recharacterization rule

That said, the new amendments, in conjunction with the existing rules, will likely lead to increased scrutiny of the activities of investment limited partnerships and may provide additional scope for … CRA … to assert on audit that partnership distributions (or portions thereof) should be characterized as taxable fees for services, as well as for disputes regarding the fair market value for such services. ...

IP can be valued using the relief-from-royalty method

Summary of Peter Neelands and Suzy Lendvay, "Valuation of IP based on a royalty stream", The Lawyer's Daily (LexisNexis Canada), January 24, 2018 under General Concepts – FMV – Other. ...

CRA confirms that an alter ego trust is entitled to a deduction for ordinary income distributions in the year of death

Summary of 2 May 2018 External T.I. 2017-0717831E5 under s. 104(6)(b) – B – s. ...

CRA finds that s. 75(2) does not apply to the deemed s. 104(4) capital gain arising in an alter ego trust on the life beneficiary’s death

Summaries of 29 May 2018 STEP Roundtable, Q.11 under s. 104(6)(b) – B – (i). ...

CRA is establishing a “TAP” Committee, similar to the GAAR Committee, to address PPT issues

Summary of 3 December 2019 CTF Roundtable, Q.1 under Treaties – MLI – Art. 7(1). ...

CRA indicates that a corporation’s adjusted stub period accrual respecting a partnership cannot be reduced by s. 111(1)(e) losses

Summary of 12 June 2020 External T.I. 2018-0788161E5 F under s. 34.2(1)- adjusted stub period accrual – (a) – B. ...

CRA recognizes that an individual and their registered plans can constitute multiple beneficiaries under the 150 MFT beneficiary test

It also noted: Notwithstanding our general view described above, we note that the CRA has previously applied … GAAR … in situations where mutual fund trust status was artificially achieved to facilitate abusive tax avoidance. ...

CRA confirms that amended invoices can be issued to evidence the HST payable

Where there are no contractual or common law restrictions to prevent the issuance of amended or additional invoices, the … CRA … will accept that the disclosure of an amount of tax payable may be met after the fact. ...

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Sierra Metals is relying on a preliminary internal sale to qualify its capital distribution of a subsidiary under s. 84(4.1)

CRA extends the effective date for applying advantage tax, where RRSP or TFSA fees are paid by the annuitant or holder, to 2019

The proposed ETA s. 272.1(8) is not a general partner distribution recharacterization rule

IP can be valued using the relief-from-royalty method

CRA confirms that an alter ego trust is entitled to a deduction for ordinary income distributions in the year of death

CRA finds that s. 75(2) does not apply to the deemed s. 104(4) capital gain arising in an alter ego trust on the life beneficiary’s death

CRA is establishing a “TAP” Committee, similar to the GAAR Committee, to address PPT issues

CRA indicates that a corporation’s adjusted stub period accrual respecting a partnership cannot be reduced by s. 111(1)(e) losses

CRA recognizes that an individual and their registered plans can constitute multiple beneficiaries under the 150 MFT beneficiary test

CRA confirms that amended invoices can be issued to evidence the HST payable

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