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Article Summary
Mark D. Brender, Marc Richardson Arnould, Patrick Marley, "Cross-Border Cash-Pooling Arrangements Involving Canadian Subsidiaries: A Technical Minefield", Tax Management International Journal, 2014, p. 345. -- summary under Subsection 247(2)
[fn 6: … 2003-0033891E5] This statement is not to be taken to mean that there is an automatic exemption from the transfer pricing rules because of the mere existence of a specific provision that targets certain intra-group financing arrangements in a cross-border context; rather, the more specific provisions should be applied first and, if they do not apply, the application of the transfer pricing rules should be considered. ...
Article Summary
Ian Bradley, "Living with the Foreign Affiliate Dumping Rules", Canadian Tax Journal (2013) 61:4, 1147-66. -- summary under Paragraph 212.3(25)(b)
. … If a CRIC owned by a limited partnership is considered to be controlled by the general partner, the FA dumping rules could produce unexpected results. ...
Article Summary
Michael Shields, "Taxation of International Shipping Companies in Canada", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 1 -- summary under Paragraph 81(1)(c)
[fn 20: The Branch Exemption found in paragraph 81(l)(c) only provides that the international shipping income earned by the foreign taxpayer is not subject to Canadian income tax – it does not provide that the company is not carrying on business in Canada….]… For a large international shipping company with significant employees in Canada, this result could mean filing hundreds of nil returns...each year. ...
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 Section 224.1
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper-- summary under Section 224.1 Summary Under Tax Topics- Income Tax Act- Section 224.1 Limitations on CRA compensation (set-off) rights (p. 13:36) While Revenu Québec followed the decision in DIMS Construction [fn 111: … 2005 SCC 52] with regards to formal bankruptcies, until quite recently it continued to apply the compensation mechanism to use post-insolvency refunds owed to the tax debtor to reduce pre-insolvency debts when the debtor was the subject of an approved proposal under the BIA. ...
Article Summary
Angelo Nikolakakis, "Guess Who's Back? The Revised Stub Period Rule for FAPI", International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 8 -- summary under Subsection 91(1.4)
. …] NAL ambiguity could invalidate s. 91(1.4) election (p. 12) …[A]mbiguity in relation to factual non-arm's length relationships could result in an invalid election. ...
Article Summary
Angelo Nikolakakis, "Guess Who's Back? The Revised Stub Period Rule for FAPI", International Tax, CCH Wolters Kluwer, No. 90, October 2016, p. 8 -- summary under Subsection 91(1.5)
. … [I]t is not clear why this measure is elective, since it is difficult to see a circumstance where this result would not be desirable from the perspective of the particular taxpayer,… [T]his measure may, to some extent, be helpful in non-arm's length situations involving transfers (or other acquisitions and dispositions) involving corporations and individuals or trusts. ...
Article Summary
Sabrina Wong, Sania Ilahi, "Tax Implications of Asset Securitizations", 2015 CTF Annual Conference Report -- summary under Paragraph 1100(2.2)(f)
. … [L]eased equipment that is acquired with the intention of immediately selling it to the limited partnership may not be considered to be depreciable property. ...
Article Summary
Ian Bradley, Denny Kwan, Dian Wang, "Is The Back-to-Back Withholding Tax Regime an Effective Anti-Treaty-shopping Measure?", Canadian Tax Journal, (2016) 64:4, 833-58 -- summary under Paragraph 212(3.9)(b)
In order to rely on the exemption from withholding tax under the Canada-US treaty [fn 61: … at article XII(3)(b)] the Canadian requests a representation from the licensor that there is no licensing arrangement that may be caught by the connection test in the back-to-back rules. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under (2)-(41)
Putter … [F.n.168 2014 MBQB 254] appear to support the CRA's position. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Taxation of Trusts Resident in Canada", Chapter 3 of Canadian Taxation of Trusts, (Canadian Tax Foundation), 2016. -- summary under Subsection 118.1(6)
[F.n.259 – CRA document no. 2013-0486701E5, July 15, 2013.] For example, assume that a trust holds private company shares with a fair market value of $1 million and a $100,000 cost, and it wants to donate the shares to a private foundation. ...