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A had been actively engaged on a regular, continuous and substantial basis for many years – but Mr. ... Summaries of 27 November 2018, Q.9 under s. 120.4(1) – excluded amount – (e)(i), and excluded share – (c). ...

This constituted a direction to SAPL to pay PBS rather than PepsiCo or SVC …. PepsiCo and SVC … were entitled to receive the payments under the EBAs and directed SAPL to pay PBS. ... Summary of PepsiCo, Inc v Commissioner of Taxation [2023] FCA 1490 under Treaties – Income Tax Conventions – Art. 12. ...

22 August 2018- 12:43am CRA rules on cross-border butterfly including steps to come within “permitted exchange” Email this Content CRA ruled on a cross-border butterfly which entailed assets of the “Transferred Business” being transferred indirectly to a wholly-owned non-resident subsidiary (Foreign Spinco) of a non-resident public company (Foreign Parentco) or to a wholly-owned non-resident subsidiary of Foreign Spinco (Foreign Spinco Sub) – with a view to the shares of Foreign Spinco being dividended out to the shareholders of Foreign Parentco at the transactions’ completion. One of the indirect assets of Foreign Parentco was a Canadian corporation (DC) which held the Canadian portions of both the Transferred Business and the “Retained Business” – hence the need for a cross-border butterfly. ... Summaries of 2017 Ruling 2017-0699201R3 under s. 55(1) – distribution, s. 55(1) – permitted distribution – para. ...

21 August 2022- 11:26pm Finance appears to be intent on introducing some sort of economic substance test into the GAAR rule Email this Content Comments of Finance in its discussion paper on GAAR include: It may be appropriate to provide that a “ bona fide purpose” does not include foreign (or provincial) tax savings (contrary to what was suggested obiter by the TCC in Loblaw). ... In this regard [:] … First, it is necessary to define economic substance so that it is possible to determine when it is lacking. ... Summaries of “Modernizing and Strengthening the General Anti-Avoidance Rule,” Department of Finance Consultation Paper, 11 August 2022 under s. 245(3), s. 245(4) and s. 245(1) – transaction. ...

Summary of 2017 Quebec CPA Roundtable, Q.1.8, 2016-0674851C6 Tr under s. 118.05(1) – qualifying home – para. ...

Summary of Milestone Apartments REIT Circular under Spin-offs & Distributions – REIT sales proceeds distribution. ...

Summaries of 2016 Ruling 2015-0614081R3 under s. 66(12.71) and s. 66.1(6) – CEE – (f). ...

Canada (Attorney General), 2018 ONCA 562 under General Concepts – Rectification & Rescission. ...

Summary of Thomson Reuters Circular and Press Release under Spin-offs & Distributions – S. 86 cash distributions. ...

Summary of Maxar Technologies Circular under Other – Continuances/Migrations – New Non-Resident Holdco. ...