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If the UWA has the UWs acquire the FTS and then sell them to the intended subscribers, … the initial subscriber is the UW and the intended subscribers are subsequent purchasers who are not technically entitled to any renunciations. ... No need to contractually preclude general common law right to sue (p. 12:23) Most provinces have certain statutory rights of rescission. … All subscription agreements will generally have a covenant that the PBC will indemnify FTS holders if the tax deductions promised are not delivered. ...

Govindadeva Bernier, Tim Scholz, "Income Sprinkling Using Private Corporations", Office of the Parliamentary Budget Officer (with thanks to “Finance Canada officials for their helpful technical discussions”), 8 March 2018-- summary under Subsection 120.4(3) Summary Under Tax Topics- Income Tax Act- Section 120.4- Subsection 120.4(3) 95% of additional federal tax to be collected from families with taxable income over $150,000 The Parliamentary Budget Officer (PBO) … computed possible revenue outcomes for the government based on three different scenarios. ... This is our preferred scenario. … Under scenario 1, PBO’s preferred scenario, the new policy changes would result in an estimated $589-million increase in taxation revenues [for 2018-19], $356 million or 60 per cent of which would go to the federal government. ...

It might seem that subsection 55(2) will not apply because the dividends are less than the safe income ($250 < $300), but this is not the case. For the old shares, Holdco has $200 of safe income (100 x ($1 + $1)) and $125 of dividends (100 x $1.25). ...

Dov Begun, "Equity Based Compensation and Stock Options", 2017 Annual CTF Conference draft paper-- summary under Subsection 5(1) Summary Under Tax Topics- Income Tax Act- Section 5- Subsection 5(1) Need to avoid constructive receipt under a phantom plan (p. 4) The CRA … interprets the word “received” in the ITA as referring to amounts constructively received as well as actually received…. [1984 CTF Roundtable, Q.13]... ... [fn 10: 2014-0535951E5]… DSU plans may also be structured to provide for dividend equivalents in the same manner as described above for RSUs. … As the stock price approaches the peak of the cycle, DSUs might actually provide an incentive for top executives to leave as it is only on employment termination that the value of the DSUs can be realized. ...

IV tax under s. 186(1)(b) – a tax deferral. Suppose, instead, that on March 31, being a day that Opco and Bankco are not connected, a dividend is paid both by Opco to the trust, and by the trust to Bankco – but on September 30, a share ownership change results in Opco and Bankco now being connected, so that CRA’s position suggests that Pt. ...

", Canadian Tax Journal (2021) 69:2, 595- 627-- summary under Subparagraph 5901(2)(b)(i) Summary Under Tax Topics- Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b)- Subparagraph 5901(2)(b)(i) Whether the holding of an interest in the FA by an LP with unrelated CRICs or their FAs as members precludes making the election (pp. 605-608) Interpreted literally, the Reg. 5901(2)(b)(ii) precludes the election- for a whole dividend paid by a foreign affiliate (FA) of a corporation resident in Canada (a “CRIC”) to come out of preacquisition surplus – if any other CRIC (or a foreign affiliate of any other CRIC) is a member of a partnership that is a shareholder of the FA, regardless whether the other CRIC is related to the particular CRIC, or the partnership is a recipient of any portion of the dividend. However, 2020 IFA Roundtable, Q.7 found that where Canco1 owned 100% of the Class A shares, and a limited partnership (LP) with partners (including Canco 2) at arm’s length with Canco1 owned 100% of the Class B shares, of a foreign affiliate (FA) respecting Canco1 and 2, and FA paid a dividend to Canco1 on the Class A shares, the Reg. 5901(2)(b)(ii)(A) requirement, that no member of LP (i.e., Canco 2) be a corporation that is otherwise eligible to elect under Reg. 5901(2)(b)(i), was only applicable where such LP in fact was receiving a dividend that otherwise could be elected upon to reduce the ACB of shares, so that Canco1 was not disqualified from making the election – but that the Reg. 5901(2)(b)(ii)(A) tainting of a dividend by FA to Canco1 (and Canco 2) would apply if FA had only one class of shares and a dividend was paid on a pro rata basis to both Canco1 and LP. ...

Uncertain reporting requirements for transactions with recurring benefits (pp. 15-16) It is unclear whether transactions need to be reported on a recurring basis and whether the sample list of notifiable transactions describes transactions that may provide tax benefits over a period of time – for example, would a transaction whereby CCPC status was lost before 2022 need to be reported because refundable taxes on investment income were avoided for subsequent years? ... Reporting obligations may arise before a series is completed (pp. 17-18) A series of transactions can encompass many years – much longer than the 45-day reporting window- and some of the examples (e.g., avoidance of deemed dispositions of trust property) deal with series where some steps may occur well into the future or not at all. ...

Need for monitoring and dealing with existing loans (p. 10) Where there is intended reliance on the moneylending business exception, there will need to be a calculation of the percentage representing the moneylending to entities within the group, during all of the time in which the loan is outstanding – which will create pressures given that loan balances may vary on a daily basis. This amendment applies not only to loans made after 2022, but also to any portion of a particular loan made before 2023 that remains outstanding on January 1, 2023 as if that portion were a separate loan that was made on January 1, 2023 – so that taxpayers may be required to take remedial action in respect of pre-existing upstream loans. ...

Nat Boidman, Eivan Sulaiman, "The EIFEL Proposals and Controlled Foreign Affiliates", Vol. 2, No. 1, February 2023, p. 5-- summary under Clause 95(2)(f.11)(ii)(D) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(f.11)- Subparagraph 95(2)(f.11)(ii)- Clause 95(2)(f.11)(ii)(D) Base example of consolidated percentage EIFEL denial to CFA and Canco (p. 6) Canco, which has business income of $1,100 after deducting interest expense of $1,400 also has a wholly-owned CFA that has income from property of $400 after deducting interest expense of $600, and pays no tax – so that Canco’s income including FAPI is $1,500. ... Inclusion of RAIFE even where FAPL (p. 7) If the CFA had incurred a foreign accrual property loss (FAPL) instead of FAPI, the RAIFE of the CFA would nonetheless be included in the IFE of Canco – even though that FAPL might never be deducted in computing Canco’s income. ...

-resident children and contributed an aggregate of $10 million to the trust over the following 10 years – but his brother, a U.S. citizen and Canadian resident, over the same 10-year period gave an aggregate of $100,000 cash to the trust to take advantage of his applicable credit (part of the $12.92 million amount) or his annual exclusion limit (currently, $18,000). The adverse consequences of s. 94 applying can be ameliorated by making a resident portion election under s. 94(3)(f) – but this election cannot be made if the trust has already filed a return for a year in which it was deemed resident pursuant to s. 94. ...