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Article Summary
Manjit Singh, Jillian Welch, "Retirement Compensation Arrangements and the Prohibited Investment and Advantage Rules", Taxation of Executive Compensation and Retirement, Special Pension Edition, Volume XVI, No. 4, 2012, p. 1041 at 1045. -- summary under Section 207.63
.] …. It appears, based on discussions with Finance, that the extension of liability to both the custodian and a specified beneficiary was considered necessary to ensure that liability for the taxes could be satisfied by all potential parties that may have benefited from the prohibited investment or advantage. ...
Article Summary
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35. -- summary under Class 14
. … [CRA has ruled] that the cost of building the infrastructure asset constitutes a "cost" of acquiring the concession agreement and/or non-exclusive access licence and that these costs, as such, are otherwise included in class 14. ...
Article Summary
Perry Truster, "Taxable Benefits: How Much is Taxable?", Tax For The Owner-Manager, Volume 14, Number 2, April 2014, p. 2 -- summary under Subsection 15(1)
The court stated that "[i]t seems improbable that a reasonable man would charge himself for actual savings he effected through his own efforts or through a company he controlled " (emphasis added). ...
Article Summary
Paul Stepak, J. Scott Wilkie, "Relieving and Clarifying Changes to Canadian Bump Rules", Corporate Finance, Volume XVIII, No. 3, 2012, p. 2130 at 2132: -- summary under Subparagraph 88(1)(c.4)(ii)
Scott Wilkie, "Relieving and Clarifying Changes to Canadian Bump Rules", Corporate Finance, Volume XVIII, No. 3, 2012, p. 2130 at 2132:-- summary under Subparagraph 88(1)(c.4)(ii) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.4)- Subparagraph 88(1)(c.4)(ii) Indebtedness issued for money is specified property – this rule now confirms, from and after 2001, that indebtedness issued solely for consideration consisting of money will not generally cause a bump problem if acquired by restricted persons. ...
Article Summary
Paul Stepak, J. Scott Wilkie, "Relieving and Clarifying Changes to Canadian Bump Rules", Corporate Finance, Volume XVIII, No. 3, 2012, p. 2130 at 2132: -- summary under Paragraph 88(1)(c.9)
Scott Wilkie, "Relieving and Clarifying Changes to Canadian Bump Rules", Corporate Finance, Volume XVIII, No. 3, 2012, p. 2130 at 2132:-- summary under Paragraph 88(1)(c.9) Summary Under Tax Topics- Income Tax Act- Section 88- Subsection 88(1)- Paragraph 88(1)(c.9) References to a share in the definition of specified property includes a right to acquire a share – this rule now confirms, from and after 2001, that the right to acquire a share is assimilated to a share for purposes of the relieving definition of specified property. ...
Article Summary
Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50 -- summary under Paragraph 80.6(2)(c)
CRA, Income Tax Technical News no. 21 … "…in the absence of sham…a lease is a lease and a sale is a sale. ...
Article Summary
Allan Gelkopf, Zvi Halpern-Shavim, "Five Arbitrary Differences between Corporations and Partnerships for GST/HST Purposes", Sales and Use Tax, Federated Press, Volume XIII, No. 2, 2015, p. 674. -- summary under Subsection 186(1)
[and] Miedzi Copper … significantly expand the scope of ITC entitlement for holding corporations, although the CRA has not changed its published position, apparently on the basis that the decisions were issued under the Tax Court of Canada's Informal Procedure,...The rule under subsection 186(1) only applies to related corporations. ...
Article Summary
Philip Halvorson, Dalia Hamdy, "An Overview of the Foreign Affiliate Dumping Rules", (OBA article), 23 February 2016 -- summary under Subsection 212.3(3)
[fn 5: The Advisory Panel on Canada's System of International Taxation, " Enhancing Canada's International Tax Advantage", 2008]…. ...
Article Summary
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper -- summary under Subsection 222(2)
[fn 132: … 2014 QCCA 1922] …While in Girard the stay of proceedings was issued under section 69.3 of the BIA, the language in that provision is quite similar to the stay provision in section 11.02 of the CCAA.... ...
Article Summary
Paul Barnicke, Melanie Huynh, "FA's LP Interest: Excluded Property?", (2015) vol. 23, no. 4 Canadian Tax Highlights, 4-5 -- summary under Excluded Property
This result follows because the postamble in the "excluded property " definition refers to an interest in a partnership that is owned by an FA of a taxpayer, and that taxpayer can be any taxpayer (Canco 4, in this case) and not only the taxpayer (Canco 3) referred to in the preamble. ...