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Article Summary
Richard Tremblay, 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 -- summary under Article 5
Formula One contravenes the requirement for separate-entity determination of a PE (p. 126) Philip Morris … held that an Italian corporation can be considered the permanent establishment of multiple non-resident members of the same corporate group. … [In response] paragraph 41.1 of The 20I0 Model Treaty Commentary on Article 5(7) (now paragraph 117 of the 2017 Model Treaty Commentary) states that: The determination of the existence of a permanent establishment under the rules of paragraph 1 or 5 of the Article must, however, be done separately for each company of the group. ... Control exercised analogous to that of franchisor (pp. 127-128) [T]he high degree of control provided for in its contract with Jaypee should be acceptable given FOWC's reasonable concern for preserving a quality product …. ... Inappropriate reliance on Fowler (p. 128) Fowler has never been followed in Canada …. ...
Administrative Policy summary
IC00-1R3 "Voluntary Disclosures Program" March 21, 2013 -- summary under Subsection 220(3.1)
Limitation Period on Discretion for Relief of Penalties and Interest ¶ 13. ... The taxpayer must comply with such requests within the stipulated timeframes…. iii) Penalty ¶ 38. A disclosure must involve the application, or potential application of a penalty. … In the event a penalty does not apply, the taxpayer cannot seek relief through the VDP. … iv) One Year Past Due ¶ 39. ...
Article Summary
Joint Committee, "Impact of CAE case", 11 August 2023 Submission of the Joint Committee -- summary under Government Assistance
Joint Committee, "Impact of CAE case", 11 August 2023 Submission of the Joint Committee-- summary under Government Assistance Summary Under Tax Topics- Income Tax Act- Section 127- Subsection 127(9)- Government Assistance CAE indicated that a government loan lacking sufficient "ordinary commercial terms" – including one that was made otherwise than to promote the governmental commercial interests or that has a below-market interest rate – will be considered "government assistance" within the meaning of ss. 12(1)(x) and 127(9). ... As an example, the mandates of each of the Business Development Bank of Canada, Canada Infrastructure Bank, Export Development Canada, and Farm Credit Canada include providing loan financing to projects which are desirable for socio-political reasons and which may not have fully commercial terms – thereby resulting in such loans being treated as government assistance so as to cause such projects to not be economically viable due to the increased tax burden. ...
Administrative Policy summary
GST/HST Memorandum 16.2 Penalties and Interest 9 January 2009 -- summary under Paragraph 298(1)(e)
However, there is no time limitation for assessing the following penalties: • the 6% penalty assessed under section 280; • the failure-to-file penalty under section 280.1; • the penalty for false statements and omissions under section 285; and • the third party penalty under section 285.1. ...
Administrative Policy summary
CG-032, Registered charities making grants to non-qualified donees (draft) 30 November 2022 -- summary under Qualifying Disbursement
. … [R]egistered charities that wanted to work through a non-qualified donee [formerly] could only do this in one way. Charities had to show that the activities were their own, demonstrated by maintaining ongoing direction and control over the use of their resources. 2. … With [the enactment of the qualifying disbursement rules], charities can support the activities of non-qualified donees (grantees), provided charities can show that they meet accountability requirements set out below. … 12. … [A] charity continues to be able to carry on activities using an “intermediary”, provided the charity exercises “direction and control”. … 14. ... With pooled grants, the CRA’s requirements focus on the charity implementing the following accountability tools: … ...
Administrative Policy summary
8 March 2018 CBA Commodity Tax Roundtable, Q.14 -- summary under Subsection 186(1)
CRA responded: Our position on the interpretation of section 186 … has not changed. …[W] e would, for example, apply … the Miedzi case … where a particular situation has the same facts ….. ...
Administrative Policy summary
GST/HST Memorandum 21-3 Respite Care Services January 2019 -- summary under Section 3
The CRA has defined primarily to mean more than 50%. 7. … The following factors … may be used to determine whether a premises is an establishment of a supplier: who has authority over making operational decisions in the establishment who has control of day-to-day operations of the establishment who has presence in the establishment the types of activities and routine carried on in the establishment … Example 3: attendance of such an individual at a day program of ABC … In addition to rendering care and supervision at its establishment Monday to Friday from 9 am to 3 pm, ABC includes day trips twice weekly to places such as museums, bowling alleys, and movie theatres. Since the service of providing care and supervision is rendered principally at ABC’s establishment, the supply made by ABC is an exempt supply under section 3 …. ... Throughout the day, healthy snacks are offered to the individuals at no extra cost. … The provision of care and supervision is the dominant element of the supply … [and] the transaction … constitutes a single supply of a service. ...
Article Summary
Jack Silverson, Bill Corcoran, "Issues Affecting Investments by Canadian Pension Plans in Private Equity, Infrastructure and Real Estate in Canada, the USA and Europe", 2016 Conference Report (Canadian Tax Foundation),15:1-40 -- summary under Subparagraph 149(1)(o.2)(iii)
[fn 25: … 2000-0055463, 2005-0151691E5 and 2005-0126841R3.] Requirement in s. 149(1)(o.2)(iii)(C) for income to be derived from an “investment” (pp. 15:12-13)... ... [fn 28: … Gilhooly v. M.N.R., [1945] CTC 203 (EC), Westar Mining Ltd. v. ... [fn 39: 2006-0195451R3 …] Words and Phrases derived ...
Article Summary
Rick McLean, Jeff Oldewening, Jonas Lau, "Capital Gains Stripping and Surplus Stripping", 2017 Annual CTF Conference draft paper -- summary under Subparagraph 52(3)(a)(ii)
Under clause 52(3)(a)(ii)(B), the amount of $30 that is determined under the formula "A + B" is added to ACB of the issued shares. ... Under clause 52(3)(a)(ii)(B), the amount of $30 that is determined under the formula "A + B" is added to ACB. ... Variable "B" computes to nil because paragraph 55(2.3) (b) did not apply. … If the dividend "amount" were $70, respecting recharacterization under subsection 55(2), the ACB denial rule does not apply. ...
Article Summary
Carrie Smit, "Amendments to 'Bump' Rules May Permit Foreign Shares as Deal Consideration", International Tax, No. 68, February 2013, p.1 -- summary under Subparagraph 88(1)(c.3)(i)
Carrie Smit, "Amendments to 'Bump' Rules May Permit Foreign Shares as Deal Consideration", International Tax, No. 68, February 2013, p.1-- summary under Subparagraph 88(1)(c.3)(i) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.3)- Subparagraph 88(1)(c.3)(i) … where a foreign purchaser ("Forco") sets up a Canadian acquisition corporation ("Bidco") to acquire a Canadian target company ("Canco"), and the consideration to be paid for the Canco shares includes Forco shares, the tax cost bump will not be precluded provided that not more than 10% of the value of the Forco shares is attributable to Canco's property. … From a practical perspective, the Bump Amendment favours larger foreign purchasers (which are substantially more valuable than the Canadian target company) over smaller foreign purchasers. … It is not entirely clear, however, how the timing in the Bump Amendment is intended to apply. ...