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19 November 2018- 4:34am There is a policy incoherence between Holdco redeeming or selling its Opco shares Email this Content The bifurcation rules in s. 55(5)(f) (or s. 55(2.3) for high-low stock dividends) frustrate the creation of capital dividend account to the extent that the built-in capital gain in shares is attributable to safe income on hand of the dividend payer – but only in the context of s. 55. ... Summaries of Rick McLean, Jeff Oldewening and Jonas Lau, "Capital Gains Stripping and Surplus Stripping," 2017 Annual CTF Conference draft paper under s. 55(5)(f), s. 89(1) – CDA – (a)(i), s. 52(3)(a)(ii) and s. 53(1)(b)(ii). ...

Instead, it viewed the stated purpose as “a tentative, provisional or exploratory contemplation that was conditional or dependent on future events occurring (that is, the … daughter being accepted and attending [the post-secondary institution]).” ... Summary of 1 June 2021 GST/HST Ruling 192033r2 under ETA s. 123(1) – builder – (f). ...

. … Neal Armstrong. Summaries of 18 May 2022 Internal T.I. 2018-0788761I7 F under Reg. 1102(5), Reg. 1102(5)(a)(iii), Sched, II, Class 8(b) and s. 13(21) – UCC – A. ...

A variant of this situation was the same except that a holding company (HC), resident in a non-treaty country, was interposed for non-tax reasons between Foreign MNC and FE – but with the funding for the acquisition of the Canco shares still having come from Foreign MNC. ... Summary of 15 May 2024 IFA Roundtable, Q.7 under Treaties – MLI – Art. 7(1). ...

(e) of that definition – with the Company distributing its sales proceeds as a PUC distribution to Company B. ... Summaries of 2023 Ruling 2023-0961681R3 under s. 66.1(6) – CEE – (f) and s. 66(12.71). ...

Summaries of 14 March 2024 External T.I. 2015-0596761E5 F under s. 18(1)(b) – capital expenditure v. expense – improvements v. running expense, s. 18(9) and s. 6(1)(k) – A(iv). ...

10 May 2018- 11:03pm CRA indicates that generally accumulated “other comprehensive loss” recognized under IFRS or US GAAP does not reduce retained earnings for thin cap purposes Email this Content In the course of finding that a Canadian subsidiary that prepared its financial statements only under U.S. generally-accepted accounting principles was not required to reduce its retained earnings for thin cap purposes by the amount of a separately reported OCI debit balance (i.e. an accumulated other comprehensive loss) in those financial statements, the Directorate stated: We understand that under US GAAP, OCI is a component of equity that is presented separately from retained earnings and paid-in capital …. IFRS similarly requires that OCI be presented as a separate component of equity and not included in retained earnings. … However, since the Taxpayer’s financial statements are prepared using GAAP of another country, the CRA could question the appropriateness of reporting any specific item as OCI, rather than retained earnings, where such treatment deviates from the treatment under Canadian GAAP (including IFRS) and such deviation has a significant impact on the amount of deductible interest under the thin capitalization rules. ... Summary of 19 January 2018 Internal T.I. 2017-0721641I7 under s. 18(5) – equity amount – (a)(i). ...

The definition of “pension income” in s. 118(7) – (a)(iii) refers inter alia to “a payment out of or under a registered retirement income fund.” ... Not so in the view of CRA, who stated: For an amount to be considered as “a payment out of or under a registered retirement income fund” for the purposes of subparagraph (a)(iii) of the definition of "pension income" in subsection 118(7), the amount must be paid in satisfaction of an obligation between the issuer and the annuitant of a RRIF. … [A]n amount deemed to be received under subsection 146.3(6) by the deceased last annuitant of a RRIF is not a payment provided out of or under a RRIF. ... Summary of 11 October 2019 APFF Financial Strategies and Instruments Roundtable, Q. 9 under s. 118(7) – pension income – (a)(iii). ...

A, CRA indicated that any taxable dividends received by him are considered to be derived directly or indirectly from such investment business – so that, since he is not actively engaged in that business, such amounts will not be “derived directly or indirectly from an excluded business” of Mr. A “ for the year.” Effectively, this is a finding that such amounts are not derived indirectly from the former trucking business, even though the proceeds of the sale thereof indirectly gave rise to such dividends. ... Summary of 3 December 2019 CTF Roundtable, Q.8 under s. 120.4(1) – excluded amount – (e)(ii). ...

Example 4: this is similar to Example 2 except that the contract with the insurer is split into two contracts, one of them for admin services – but this makes no difference to the result in light of the single-supply doctrine. Example 6: a non-licensed insurer covers any major collision or theft loss of new car purchasers who enter into a contract with it – given that it is not a licensed insurer, this contract is not considered to be the provision of an exempt insurance service (although such corporation’s coverage, in turn, from the insurer is exempted). ... Summaries of GST/HST Notice 325 Services Provided by Certain Insurance Intermediaries July 2023 under ETA s. 123(1) – financial service – para. ...