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Article Summary
Lucie Lamarre ACJ, Isida Ranxi, "Taxpayer Rights and Voluntary Compliance: The Example of the Canadian Judiciary", Tax Notes International, 3 October 2016, p. 61 -- summary under Evidence
. … [T]he appearance of fairness has another aspect — that is, how the proceedings appear to the unrepresented party. ...
Article Summary
Manal Corwin, Jesse Eggert, "Understanding the Operation, Impact, and Practical Implications of the MLI", Tax Management International Journal, Vol. 46, No. 8, 11 August 2017, p. 407 -- summary under Article 7
Those treaties fall into several categories: • Treaties that already contain a PPT that is narrower than the new PPT; • Treaties that did not contain a PPT, but were between countries with experience applying PPT- type rules to their tax treaties; and • Treaties that did not contain a PPT, and were between countries without experience applying PPT- type rules. ...
Administrative Policy summary
GST/HST Memorandum 13.5 Non-creditable Tax Charged January 2017 -- summary under Paragraph 171(4)(b)
Example 11 – Adjustment to net tax for rental property on becoming a small supplier division In July, a registrant PSB resident in Ontario that has a monthly reporting period prepays the monthly rent of $1,500 plus HST for six months (July through to December) for the building in Ontario used by its division in commercial activities. The total amount of rent prepaid is $9,000 ($1,500 × 6 months) plus $1,170 in HST ($9,000 × 13%). ... The PSB is required to add to its net tax an amount of $585 ([$1,500 × 13%] × 3), which is accounted for by the PSB on line 104 (or on line 105 if filing electronically) of its October GST/HST return. ...
Article Summary
Didier Fréchette, Ryan Rabinovitch, "Current Issues Involving Foreign Exchange", 2015 CTF Annual Conference paper -- summary under Subsection 84(3)
. … [A]ccording to [9634245], it is not possible to specify an amount in foreign currency. … [T]his interpretation is arguably inconsistent with the tax policy underlying subsections 191(4) and (5)… [and] with [CRA's] position regarding the application of section 51.1.... ...
Article Summary
Nathan Boidman, "Anson and U.S. LLCs: A Canadian Perspective", Tax Notes International, August 3, 2015, p. 439. -- summary under Corporation
The short answer appears to be — no…. Misinterpretation of effect of LLC Agreement (p. 439) First, with respect, the decision — that section 4.2 of the LLC agreement (together with certain provisions of the Delaware LLC Act) that required that profits be allocated to LLC owner capital accounts immediately vested those profits in the owners — seems to be wrong. ...
Article Summary
Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report -- summary under Subsection 1100(16)
. … [T]he lease originator transfers the equipment that is subject to the underlying leases at fair market value to an SPE, often a limited partnership, in consideration…for limited partnership interests, assumed liabilities, and a note issued by the limited partnership…under subsection 97(2). … The limited partnership issues asset-backed notes, either directly to investors or to a conduit trust (that in turn issues commercial paper to investors). ... Alternatively, they can elect to include one or more exempt properties in a separate class for CCA purposes. … [S]ince the principal leasing business requirement must be met throughout each taxation year, including the first taxation year of a newly formed SPE, it is common to transfer a few leased pieces of equipment to the SPE at the time of its formation. ... This issue was raised in a CRA technical interpretation [2002-0156515 where] … A Co, B Co, and C Co each retained 10 percent of the leased equipment. … It is the CRA's position [in IT-443, para. 10] that the gross revenue of the partnership from a particular source is to be included in the gross revenue of the corporation from that source to the extent of the corporation's profit-sharing percentage. … [I]f the activities of the corporation and the partnership are considered to be two separate businesses of the corporation, the following determinations must be made: (1) which business is the corporation's principal business, (2) whether this principal business is the leasing of leasing property, and (3) whether the gross revenue from that principal business is at least 90 percent of the gross revenue of the corporation for the year from all sources. ...
Administrative Policy summary
Excise and GST/HST News - No. 114, August 2023 -- summary under Subsection 280(1)
Excise and GST/HST News- No. 114, August 2023-- summary under Subsection 280(1) Summary Under Tax Topics- Excise Tax Act- Section 280- Subsection 280(1) P-194R2 cancelled in light of Villa Ste-Rose GST/HST Policy Statement P-194R2 Application of Penalties and Interest when a Return and/or Rebate Application, and/or Another Return, is Received After the Due Date was cancelled on May 10, 2023 …. [D]ue to decisions rendered … [in] Villa Ste-Rose … the policy is now obsolete. ...
Article Summary
Nigel P.J. Johnston, Roger E. Taylor, "Taxation of Hedges and Derivatives: Recent Developments", 2016 Conference Report (Canadian Tax Foundation), 13:1-36 -- summary under Subparagraph (b)(iii)
Assume that the current spot rate for the Canadian dollar is US$1 = Cdn$1.25 and the taxpayer enters into an agreement to sell US$1 million a year from now at the forward rate of US$1 = Cdn$ 1.2685. If in a year's time the spot rate is US$1 = Cdn$1.20 (that is, the Canadian dollar has appreciated against the US dollar), the taxpayer realizes a gain of Cdn $68,500 (by selling US$1 million for Cdn$l,268,500 rather than at the spot rate of Cdn$1.20 or Cdn$1.2 million). ...
Administrative Policy summary
T2059 Election on Disposition of Property by a Taxpayer to a Canadian Partnership -- summary under Subsection 97(2)
T2059 Election on Disposition of Property by a Taxpayer to a Canadian Partnership-- summary under Subsection 97(2) Summary Under Tax Topics- Income Tax Act- Section 97- Subsection 97(2) Filing instructions (different where co-ownership) Mail one copy of this election and related schedules (as specified), completed by the transferor as follows: – to the tax centre of the transferor – on or before the earliest date on which any party to the election has to file an income tax return for the tax year in which the transaction occurred (due date). This due date must consider any election under subsection 25(1) or 99(2) – separately from any other return • When many transferors elect to transfer the same property (co-ownership) or many members of the same partnership elect to transfer their partnership interests, the elections will be processed together and should be filed: – to the tax centre of the transferee – on or before the due date – by a designated transferor to file all of the completed forms for each transferor, together with a list of all of the electing transferors. This list should contain the name, address and social insurance, trust account or business number of each transferor and of each member of the transferee – separately from any other return ...
Administrative Policy summary
28 February 2019 CBA Roundtable, Q.27 -- summary under Paragraph 254(4)(a)
. … [T]he word “ownership” generally refers to the legal ownership (that is, “titled” ownership in the case of the underlying real property), rather than equitable ownership of the property. … Based on the assumptions that: (a) the Builder has actual possession of the Developed Lots or the Developed Land pursuant to the Sale Agreement, and (b) the Sale Agreement provides that beneficial ownership of the House or Unit situated on the Developed Lot or Developed Land (as the case may be) is transferred to the Builder at Initial Closing, one could argue that the Developer holds legal ownership for the benefit of the Builder and is required to transfer legal ownership to the Builder on demand, or to any third party at the Builder’s request (for example, to the Home Buyer …). So, with respect to this scenario, provided that legal ownership is transferred from the Developer, at the Builder’s direction at Subsequent Closing, to the Home Buyer who is the particular individual with whom the Builder has entered into the Home Buyer Agreement, the CRA will … regard the Builder as having transferred ownership of the House or Unit … to the Home Buyer …. Therefore … provided that all of the other conditions … are met, the Builder may pay or credit the Rebate to the Home Buyer. ...