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Summary of 17 August 2021 GST/HST Interpretation 207227 under ETA s. 123(1)- financial service – para. ...

Summary of 14 January 2022 Internal T.I. 2021-0913891I7 under s. 125.7(1) – qualifying rent expense. ...

Summary of Circular of Cominar Real Estate Investment Trust regarding its acquisition by Iris Acquisition II LP (the “Purchaser”) under Mergers & Acquisitions- REIT/Income Fund/LP Acquisitions- LP Acquisitions of Trusts. ...

A “publicly traded company” is “a company the shares … of which are listed or traded on a stock exchange or other public market” and “would include [such] a non-resident company.” ...

Summary of 1 June 2021 Internal T.I. 2020-0858471I7 F under s. 110.2(1) – qualifying amount- (a). ...

Summaries of 15 June 2021 Internal T.I. 2020-0867081I7 under s. 104(24), s. 248(1) – GRE, and s. 104(27). ...

The trusts were then to engage in pipeline transactions in which the two companies’ shares were to be transferred to a ULC Newco in consideration mostly for notes, and then convert those notes to high-PUC shares of the ULC – and only after a number of years, might ULC be amalgamated with the two companies (which would have been continued to the same jurisdiction as the ULC). ...

In contrast, a foreign life insurance policy (which would not be an “excluded right or interest” under s. 128.1(10) – (f)) held by a non-resident corporation when it became resident in Canada would not be subject to s. 70(5.3), and for purposes of determining its deemed cost under s. 128.1(1)(c), “would be valued in accordance with normal valuation practices taking into consideration all facts relevant to the particular case.” ...

. … In determining if an apportionment provided under a mixed contract is reflective of the obligation of the parties under subsection 212(1), consideration would be given, amongst others, to the terms of the mixed contract and to whether the parties have divergent interests in respect of this apportionment. ...

. … CRA went on to list various types of documentation that it “may” require, depending on the circumstances, including non-consolidated financial statements, minute books, and tax returns of the FA and supporting documentation illuminating the nature of its business and income and related to its transactions. ...