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Summary of Richard Tremblay and Ilana Ludwin, "Indian Supreme Court Diverges from OECD Guidelines, Relies on Questionable Canadian Precedent, in Deciding PE Issue in Formula One," Tax Management International Journal, 2018, p. 125 under Treaties – Income Tax Conventions- Art. 5. ...

Although this sounds ominous, CRA went on to indicate that the taxpayer’s exemption threshold in this situation would be nil “it is necessary for the taxpayer to have acquired a flow-through share (or certain partnership interests …) in order for a taxpayer to have an exemption threshold in respect of a flow-through share class of property to which subsection 40(12) of the Act would apply.” ...

Summary of BSR REIT preliminary prospectus under Offerings – REIT and LP Offerings- Cross-Border REITs. ...

CRA’s reasoning was that the only interest referenced in this definition was interest that was “paid or payable” – so that the contingent interest could be ignored until it became payable by virtue of the occurrence of the price trigger. ...

Summaries of 7 February 2018 External T.I. 2016-0673331E5 under s. 9 – computation of profit. ...

Parent then amalgamated with Target and the Subco shares were bumped under s. 88(1)(d) – but with the bump amount being reduced by any Subco surpluses described in Reg. 5905(5.4). ...

However, as CRA does not take into account interest relating to acquisitions by a partnership of FA shares for 93.1(2)(d)(i) limit purposes, the s. 113(1) deduction of Canco is $1,000 rather than $700 – so that in computing its taxable income, Canco would have a loss of $300 (i.e., partnership income of $700, minus a s. 113(1)(a) deduction of $1,000). ...

The fact that the Delaware & Florida LLP or LLLP resulted from a previous conversion from an LLC would not by itself prevent accessing the grandfathering relief. ...

Summary of 29 May 2018 STEP Roundtable, Q.5 under s. 120.4(1) – excluded shares. ...

CRA indicated that the exclusion in s. 112(3.32) from the application of s. 112(3.2)(b) should apply where an estate has received an s. 84(3) deemed dividend on a redemption, it designates that dividend, distributes it to the spousal trust, and the spousal trust in turn designates and pays it to the individual beneficiary – so that the taxable dividend does not reduce the loss. ...