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A public-company acquiror “obtains specific contractual covenants and/or indemnities from the Target and the significant shareholders of the Target … that are intended to ensure the Target and/or the significant shareholders do not take certain steps that may cause the bump denial rules to apply ….” ... Summaries of Mandatory disclosure rules – Guidance, 7 June 2023 CRA Webpage under s. 237.3(1) – reportable transaction – (a), confidential protection, contractual protection, s. 237.4(6), s. 237.4(7), s. 237.5(1)- reportable uncertain tax treatment. ...

The beneficiaries then used their sales proceeds to subscribe for the shares of a newly-incorporated holding company (Holdco): Trust – 50% of the Holdco shares; Mr. and Mrs. X – 20% each; and Child X and Y – 5% each). Holdco generated $150,000 from investing these funds in the stock market and paid a $100,000 dividend pro rata to its shareholders with Trust, in turn, distributing its $50,000 dividend to Mrs. ... Summaries of 5 October 2018 APFF Roundtable, Q.13 under s. 120.4(1) – excluded shares, excluded amount – (e)(i) and arm’s length capital. ...

Summary of 7 October 2016 APFF Roundtable, Q.6 under s. 118.1(1) – total charitable gift – s. ...

Summary of 8 October 2021 APFF Financial Strategies and Instruments Roundtable, Q.11 under s. 233.3 – specified foreign property – (a). ...

A filing generally is not required where the Canadian taxpayer participating in the cash pooling arrangement is solely a creditor …. ... Summaries of “Mandatory disclosure rules – Guidance,” 15 August 2024 CRA Webpage under s. 237.3(1) – reportable transaction – (a), contractual protection and s. 237.4(3). ...

18 September 2016- 2:18am CRA considers that a parking space can form part of a condo unit for principal residence exemption purposes Email this Content CRA accepts that when a parking space was acquired as part of the purchase of a residential condo unit, the parking space can thereafter form part of the condo unit (viewed as a “housing unit” for principal residence exemption purposes) provided that the parking space facilitates the use of the housing unit (which presumably would always be the case if it is actually used by the condo owner) and it is part of the common or private area for the same building – and this is so even if the parking space as a matter of real property law is separate from the condo unit. ... Summary of 10 June 2016 External T.I. 2015-0590371E5 Tr under s. 54 – principal residence – s. ...

In particular, Banro’s shares of BGB will be cancelled, BGB will issue shares to a newly-formed Caymans company (Newco) for nominal consideration, and the secured creditors will receive shares of Newco in satisfaction of their secured claims against BGB – except that 25% of their claims will instead be treated as unsecured claims. ... Summary of Banro Circular under Public Transactions – Other- Recapitalizations – Debt into common equity. ...

Leaving aside s. 55(2), over ¾ of the purchase price was deemed to be a dividend. ... Summary of Thomson Reuters Circular under Other – Issuer Bids – Share Offer. ...

After indicating that the “exempt contribution” definition in s. 207 did not “require that the survivor payment be received before the contribution is paid,” CRA noted that the definition requires that the contribution be designated on a Form RC240 within 30 days after the day on which the contribution is made (or at any later time that is acceptable to the Minister) – which meant that Ms. ... Summary of 11 October 2019 APFF Financial Strategies and Instruments Roundtable, Q.5 under s. 207.01(1) – exempt contribution – (c). ...

B are also subject to TOSI – thereby perhaps resulting (if she is an Ontario resident) in an effective tax rate of 107%. ... Summary of Stan Shadrin, Manu Kakkar and Alex Ghani, "FAPI and TOSI Overlap: 107 Percent Tax is Not Fair", Tax for the Owner-Manager, Vol. 20, No. 1, January 2020, p.5 under s. 120.4(1) – split income – (a). ...