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Article Summary
Benjamin Alarie, Julia Lockhart, "The Importance of Family Resemblance: Series of Transactions After Copthorne", Canadian Tax Journal (2014) 62:1, 273-99. -- summary under Subsection 248(10)
D.A.I., 2012 SCC 5, at paragraph 31.]… Breaking of series by intervening event (p. 84) One possible standard to consider for intervening events comes from the field of tort law: the concept of novus actus interveniens …. ... & R. Simard Inc. v. The Queen, for example, Tardif J wrote that a 12-month interval constituted a "long period of time" for the purpose of determining whether a series existed. ... [fn 67: … 2009 FCA 163, at paragraph 51.] Meaning of "family resemblance" (pp. 90-1) Milet has explained the idea of family resemblance as follows: [T]he various instances of a general term's application would be linked by, as Wittgenstein called them, "family resemblances" – the reference here being to the way that traits are shared by and dispersed among members of a family: for instance, a girl has red hair and is short like her father and grandmother, while her brother, who is also red-haired, is tall like his blond mother. ...
Article Summary
Michael Coburn, "Practical Strategies for Dealing with the Restrictive Covenant Provisions", 2014 Conference Report (Canadian Tax Foundation), 8:1-29 -- summary under Paragraph 68(c)
Specifically, the Federal Court of Appeal in Transalta … cited with approval the reasonableness standard set out in Gabco … […68 DTC 5210.] ...
Administrative Policy summary
Excise and GST/HST News - No. 108 September 2020 -- summary under Paragraph 232(3)(a)
. … The amount of the forgivable loan will equal 50% of the monthly gross rent payable by the impacted small business tenant during the 4-month period. ... Generally, the remaining part of the refund or adjustment (that is, the difference between the amount of the rent reduction and the amount of the forgivable loan) must be borne by the commercial property owner. … No GST/HST collectible by CMHC on forgivable loans GST/HST implications There is no GST/HST applicable with respect to payments received by the commercial property owners from CMHC under the CECRA program. … The forgivable loans provided by CMHC under the CECRA program are exempt supplies of financial services. … Requirement to follow s. 232 re rent reductions Application of GST/HST to refunds or adjustments of the gross monthly rent paid or payable The rent reduction agreement … has the effect of reducing the amount of consideration payable for a taxable supply of real property made by way of lease, licence or similar arrangement …. … [P]ursuant to a rent reduction agreement, a commercial property owner agrees to subsequently reduce an impacted small business tenant’s monthly gross rent payable by at least 75% for the 4-month period. Pursuant to section 232 … in this case where a commercial property owner agrees to refund or credit an amount of GST/HST already collected, or agrees to adjust the GST/HST applicable to the reduction of the monthly gross rent payable, the commercial property owner must issue a credit note, meeting the prescribed requirements that are set out in the Act, to the impacted small business tenant. ...
Article Summary
Angelo Discepola, Robert Nearing, "A Reply to the CRA's Classification of Florida and Delaware LLLPs and LLPs as Corporations", 2016 Conference Report (Canadian Tax Foundation), 24:1-39 -- summary under Section 96
. … [T]here is a strong argument that the IA definition applies for greater certainty to ensure that LLLPs and LLPs are not treated as corporations. ... [fn 106: See Gerling Global …. v. Canadian Occidental…, 1998 ABQB 714. ... Relevance and extent of limited liability (pp. 24:29 – 32) [O]PA LLPs are also full-shield LLPs [fn 107: Section 10(2) of the OPA] and the CRA has to date treated these LLPs as partnerships for Canadian tax purposes. ...
Article Summary
Anu Nijhawan, "When is 'Loss Trading' Permissible: A Purposive Analysis of Subsection 111(5)", 2015 CTF Annual Conference paper -- summary under Paragraph 111(5)(a)
The loss business was broadly identified as marine construction, rather than being limited to marine construction in a specific location, based upon evidence that marine construction businesses typically operate in various areas throughout the country; [fn: 50: Canadian Dredge & Dock Co. v. ... The loss business was found to be selling clothes, whether those clothes were sold to individuals or to retail and wholesale merchants, and whether they were ladies' clothing or men's and boy's clothing; [fn 53: Martin & Co. ...
Article Summary
Michael Colborne, Michael McLaren, Mark Barbour, "Subsection 247(3): What are "Reasonable Efforts"?", Canadian Tax Journal, (2016) 64:1, 229-43 -- summary under Subsection 247(3)
[fn 31: … 1995 OECD guidelines, at paragraph 5.28 (emphasis added). … the need for the documents should be balanced by the costs and administrative burdens, particularly where this process suggests the creation of documents that would not otherwise be prepared or referred to in the absence of tax considerations. ... What is reasonable is based on what a reasonable business person in the taxpayer's circumstances would do, having regard to the complexity and importance of the transfer pricing issues that arise in the taxpayer's case. … [R]egardless, we have seen the CRA assert penalties in circumstances where it ought to be uncontroversial that reasonable efforts were made. ...
Article Summary
Jenny Yu, "Departure Tax for Small Trusts", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 8 -- summary under Subsection 220(4.51)
Jenny Yu, "Departure Tax for Small Trusts", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 8-- summary under Subsection 220(4.51) Summary Under Tax Topics- Income Tax Act- Section 220- Subsection 220(4.51) No relief from security requirement for small trusts/emigration under s. 94(5) (p. 8) When an individual ceases to be a resident of Canada and has a deemed disposition of certain property…[s]ecurity is automatically considered to be posted for essentially the first $16,500 ($50,000 × 33%) of federal tax (subsection 220(4.51)). However, as the CRA has confirmed (2015-0608051E5 …), this deemed-security rule does not apply to trusts that cease to have a Canadian residence and have a corresponding departure tax.... ...
Administrative Policy summary
RC4651 “Guidance on Country-By-Country Reporting in Canada” 23 November 2018 -- summary under Subsection 233.8(6)
This replaces the 24 March 2017 version of RC4651
Note: on the RC4649, the reporting entity is either: • the UPE • an SPE – a Canadian CE that has been designated as a surrogate parent of a foreign UPE. Note: A Canadian CE cannot be designated as an SPE of a Canadian UPE • a CE, in cases of a local filing requirement Filing obligations of Canadian CE that is SPE Obligations of a surrogate parent entity in Canada A CE resident in Canada that is appointed as an SPE of a foreign UPE is subject to filing requirements as if that entity were a UPE in Canada. In particular, subsection 233.8(1) of the Act defines an SPE as a CE of an MNE group that has been appointed by the MNE group — in substitution for the UPE — to file the CbC report on behalf of the MNE group, if one or more of the conditions in subparagraph 233.8(3)(b)(ii) applies (i.e., the conditions for the secondary reporting mechanism to apply). ...
Article Summary
Josh Jones, Jeffrey Love, "Recent Developments in Asset Management", draft 2023 CTF Annual Conference paper -- summary under Paragraph (c)
(c)(iv) does not expressly address when eligible group entity status is tested, and refers to “an eligible group entity in respect of the taxpayer for the taxation year ” even though the eligible group entity definition provides a point-in-time test – perhaps an interest payment made by an entity is relevant under s. ...
Administrative Policy summary
GST/HST Memorandum 20-4 “Vocational Schools and Courses” December 2019 -- summary under Section 8
. … In addition to the diploma program, the school offers 3 courses: “Enhancing Your Webpage with Java”, which is also a credit course in the diploma program [exempt] “Programming in C++”, which is offered as an upgrade program and for which students are graded on a mid term assignment and final exam [exempt] “Supporting and Implementing Windows”, which is not offered as part of the diploma program and for which students are evaluated based on class attendance and participation Certificates are issued to students upon completion of each of the courses. … … [T]he supply of instruction in “Supporting and Implementing Windows” is not exempt under section 8 of Part III of Schedule V, regardless of the fact that a certificate is issued upon successful completion of the course. ... The CRA does not consider an individual to be under instruction and direct supervision while amassing build-up flight time hours. … 55. Where a student purchases hours of dual or solo flight time over and above the minimum time requirements in the federal legislation, the supply of the additional hours is not exempt under section 8 …. 56. ...