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Article Summary
David Carolin, Manu Kakkar, Boris Volfovsky, "Tax Alchemy and Paragraph 55(3.01)(g): Converting a 55(3)(b) Divisive Reorganization into a 55(3)(a) Related-Party Butterfly", Tax for the Owner-Manager, Vol. 24, No. 1, January 2024, p. 7 -- summary under Paragraph 55(3)(a)
See also 2015-0570021E5 F. ...
Article Summary
David M. Sherman, Bal Katlai and Kenneth Keung, "Can an Unpaid Dividend Avoid Departure Tax?", Tax for the Owner-Manager, Vol. 24, No. 1, January 2024, p. 9 -- summary under Paragraph 128.1(4)(b)
No deemed payment of dividend on emigration (p. 9) The position in 9640475 – that s. 128.1(4)(b) would apply to tax the individual on the emigration as if the declared and unpaid dividend had been paid- appears to be incorrect. ...
Article Summary
Elizabeth Boyd, Jeremy J. Herbert, "Trusts Holding Shares For Employees", draft 2023 CTF Annual Conference paper -- summary under Subsection 144(3)
When so used, advantages of the EPSP over an EBP trust include that the increase in the shares’ value from their acquisition can be received by the employee as a capital gain (in contrast to employment income under an EBP) and dividends and capital gains generated by the EPSP can retain that character when allocated to an employee – and the employer’s deduction of contributions to an EPSP is more immediate and straightforward (i.e., no need for the trustee to determine the employer’s deduction nor is it offset by income earned in the trust). ...
Article Summary
Elizabeth Boyd, Jeremy J. Herbert, "Trusts Holding Shares For Employees", draft 2023 CTF Annual Conference paper -- summary under Subsection 8(12)
Likely non-application of s. 75(2) where shares issued to s. 7(2) trust are from treasury (p. 24) Although one of the s. 8(12) requirements is that the trust have disposed of the share to the corporation that issued the share to the trust, CRA has indicated that a reversion engaging s. 75(2)(a)(i) requires the transferee to have owned the property before it was held by the trust – so that s.75(2) should not apply where the corporation’s shares were issued directly from treasury to the trust (see 2006-0218501E5, 2007-0243241C6 and 2009-0317641E5 regarding the situation where a trust subscribes for shares of a corporation for FMV consideration). ...
Article Summary
Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper -- summary under Clause 95(2)(f.11)(ii)(D)
Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper-- 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) Issues with s. 95(2)(f.11)(ii)(D) rule (pp. 12-13) S. 95(2)(f.11)(ii)(D) provides, respecting s. 95(2)(f)(ii) (but not (i)) amounts included in the RAIFE of a CFA of a Canadian taxpayer for a taxation year, for a denial of such RAIFE amounts otherwise deductible in computing FAPI in proportion to the overall denial (if any) computed under s. 18.2(2) – so that deduction of the RAIFE of the CFA is potentially subject to the same proportionate denial as for its Canadian parent in respect of the parent’s IFE (although note that s. 95(2)(f.11)(ii)(D) does not apply to an excluded entity). ...
Article Summary
Chris Lang, "Debt Restructuring Using a Reverse Vesting Order: Tax Issues", Canadian Tax Focus, Vol.15, No. 2, May 2025, p. 2 -- summary under Subsection 80(13)
Peakhill Capital Inc. (2024 BCCA 246) …. ...
Administrative Policy summary
27 February 2020 CBA Roundtable, Q.8 -- summary under Subsection 191(3)
Its reasoning: Based on … the operator … not hav[ing] an interest in the real property on which the MURC is situated, the operator does not meet the conditions set out in paragraph (a) of the definition of “builder.” ...
Administrative Policy summary
CRA News Release, “Bare trusts are exempt from trust reporting requirements for 2023,” 28 March 2024 -- summary under Subsection 150(1.2)
CRA News Release, “Bare trusts are exempt from trust reporting requirements for 2023,” 28 March 2024-- summary under Subsection 150(1.2) Summary Under Tax Topics- Income Tax Act- Section 150- Subsection 150(1.2) Cancellation of bare trust reporting obligation for calendar 2023 In recognition that the new reporting requirements for bare trusts have had an unintended impact on Canadians, the Canada Revenue Agency (CRA) will not require bare trusts to file a … T3 return … including Schedule 15 (Beneficial Ownership Information of a Trust), for the 2023 tax year, unless the CRA makes a direct request for these filings. ...
Administrative Policy summary
26 August 2019 Comfort Letter - “Advantage”: Exclusion for Investment Management Fees -- summary under Subparagraph (b)(i)
26 August 2019 Comfort Letter- “Advantage”: Exclusion for Investment Management Fees-- summary under Subparagraph (b)(i) Summary Under Tax Topics- Income Tax Act- Section 207.01- Subsection 207.01(1)- Advantage- Paragraph (b)- Subparagraph (b)(i) where RRSP or TFSA fees (described in s. 20(1)(bb)) are paid by the annuitant or holder [If] investment management fees of registered plans … are paid directly by the holder/annuitant using funds outside of the plan, the resulting indirect increase in the value of the plan assets might be viewed as an advantage … if one of the main purposes is to benefit from the tax-exempt status of the plan. Even so, we have no tax policy concerns with respect to the payment of investment management fees directly by the annuitant/holder of the registered plan. … Generally, the direct payment of fees results in either a net loss, or negligible gain, for the plan holder. We are therefore prepared to recommend … clarifi[cation] that the payment by a controlling individual (as defined in subsection 207.01(1)) of investment management fees that pertain to a registered plan does not constitute an advantage … [and] [s]pecifically … that paragraph (b) of the definition "advantage" in subsection 207.01(1) be amended [respecting 2018 and subsequent taxation years] such that it does not apply to payments by a controlling individual of a registered plan, not exceeding a reasonable amount, of fees described in paragraph 20(l)(bb) …. ...
Administrative Policy summary
FAQ - Deferral of GST/HST Tax Remittances: CRA and COVID-19 20 April 2020 CRA Webpage (as amended on June 29, 2020) -- summary under Subsection 281.1(1)
This means that no interest will apply …. The deadline for businesses to file their returns is unchanged. … However … the CRA won’t impose penalties where a return is filed late provided that it is filed by June 30th. ... Q.4 No automatic deferral for excise duties Excise taxes and duties are still required to be remitted by their prescribed due dates. … Decisions to waive interest are made on a case by case basis. ... Q.9 No payment of housing/general rebate rebate claims Only the GST/HST rebate applications filed electronically for … Point-of-Sale and Public service bodies with the CRA can be processed automatically unless they require client contact or additional review. ...