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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 104(24)
[F.n.283 – Cindy Radu and Siân Matthews, "Trust Administration—Best Practices," in 2010 Atlantic Provinces Tax Conference (Toronto: Canadian Tax Foundation, 2010), 4A:l-20. ...
Article Summary
Lorenzo Bonanno, Guy Buckley, "Limited Liability Partnerships", Canadian Tax Highlights, Vol. 25, No. 2, February 2017, p. 7 -- summary under Paragraph 40(3.14)(a)
. … Full-shield protection generally protects a partner against most partnership liabilities. ...
Article Summary
Elie Roth, Tim Youdan, Chris Anderson, Kim Brown, "Classification of Trusts for Income Tax Purposes", Chapter 2 of Canadian Taxation of Trusts (Canadian Tax Foundation), 2016. -- summary under Paragraph 20(1)(r)
[fn 220: … 2007-025985117… 2010-0388761R3] Distributions to Canadian-resident employees from the RCA are taxed in the year in which they are received under paragraph 56(1)(x), and are subject to withholding tax under paragraph 212(1)(j),… ...
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Joint Committee, "Proposed Changes to the Voluntary Disclosure Program Announced June 9, 2017", 8 August 2017 Joint Committee Submission to Finance respecting the Voluntary Disclosure Program (“VDP”) -- summary under Subsection 220(3.1)
Large corp,/ transfer-pricing exclusion (pp. 8-10) Furthermore, errors by large corporations typically are attributable to the number and complexity of the tax-reporting issues faced by them, so that their exclusion would violate fundamental principles of fairness – as does blanket denial of relief to taxpayers respecting transfer pricing errors. ...
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Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under Subparagraph 87(4.4)(d)(i)
. … …[Scenario #3] The FTS holder disposes of its FTS to purchaser 1, who then sells to purchaser 2. ...
Article Summary
Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under Paragraph 6202.1(1.1)(c)
Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39-- summary under Paragraph 6202.1(1.1)(c) Summary Under Tax Topics- Income Tax Regulations- Regulation 6202.1- Subsection 6202.1(1.1)- Paragraph 6202.1(1.1)(c) Prescribed share issues if flow-through subscription receipts (p. 12:21-22) [I]f the subscription agreement for subscription receipts were structured as FTS, a prescribed-right issue would immediately be triggered – namely, it would be possible that the holder could get the subscription price back for the subscription receipt if the escrow conditions were not met. ...
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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 28(2)
[f.n. 126: … art, 28(2)(a).] Such "free form" reservations are subject to objection by other parties, and if a party objects, Part VI will not apply at all between the reserving party and the objecting party. ...
Article Summary
Hugh Chasmar, "Corporate Class Funds", Canadian Tax Highlights, Vol. 25, No. 8, August 2017, p. 6 -- summary under Qualifying Exchange
. … In TI 9608465, the CRA concluded that in a proposed merger of two trusts (the one trust being the “top fund” and the other being the “bottom fund” of a fund-of-fund structure), the top fund could not transfer units of the bottom fund to that fund: the proposed merger was not a qualifying exchange. ...