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Article Summary
Paul Barnicke, Melanie Huynh, "Fresh-Start FA Rules", Canadian Tax Highlights, Vol. 22, No., 12, December 2014, p. 7. -- summary under Paragraph 95(2)(k)
If the fresh-start rules apply, the gain is calculated as $300 ($400- $ 100), and on the facts no further adjustment is made under paragraph 95(2)(f.l), because no part of the gain is considered to have accrued before the taxpayer acquired the non-resident. ...
Article Summary
Geoffrey S. Turner, "June 2014 Election Deadlines for Retroactive Application of New Foreign Affiliate Reorganization Rules", CCH International Tax, No. 74, February 2014, p. 1. -- summary under Paragraph 5901(2)(b)
.-- summary under Paragraph 5901(2)(b) Summary Under Tax Topics- Income Tax Regulations- Regulation 5901- Subsection 5901(2)- Paragraph 5901(2)(b) Retroactive election (p. 3) … Bill C-48 permits taxpayers to electively apply Regulation 5901(2)(b) (together as a package with subsections 90(2) and 93(1.11)) retroactively to foreign affiliate distributions made after December 20, 2002. ...
Article Summary
Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37 -- summary under Subsection 104(22)
. … Circular of Westcap Investments Corp.," July 18, 2014….] In this structure, the Blocker LP is considered to indirectly carry on business in the U.S. and accordingly is subject to U.S. corporate income tax, plus U.S. branch tax (because it has elected to be treated as a foreign corporation for U.S. tax purposes). ...
Article Summary
Manu Kakkar, "Paragraph 56.4(7)(b ) Related-Person Problem and Arm's Length Minority Acquisitions", Tax For The Owner-Manager, Volume 14, Number 2, April 2014, p. 8. -- summary under Paragraph 56.4(7)(b)
D) must grant a restrictive covenant "not to provide, directly or indirectly, property or services in competition with the property or services provided… by the purchaser (or by a person related to the purchaser) " [emphasis added]. ...
Article Summary
Edward A. Heakes, "The Proposed Revisions to Back-to-Back Loan Rules", International Tax Planning (Federated Press), Vol. XIX, No. 4, 2014, p. 1357. -- summary under Paragraph 212(3.1)(e)
. … [I]t is not clear…why the intermediary would ever be granted a security interest in respect of its own obligation]) is less than 25% of the amount owing by the Canadian taxpayer to the intermediary, the back-to-back rule will not apply. ...
Article Summary
Allan Lanthier, "Limited Liability Partnerships", Canadian Tax Highlights, Vol. 24, No. 6, June 2016, p. 10. -- summary under Section 96
. … Ms. A's fellow partners must agree to the conversion, and they may have little incentive to do so. ...
Article Summary
Michael Shields, "Taxation of International Shipping Companies in Canada", International Tax (Wolters Kluwer CCH), No. 88, June 2016, p. 1 -- summary under Subsection 250(6)
. … 250(6)(b)] In years that the company does not receive any gross revenues, it is unclear whether this test can be met. ...
Article Summary
Bruce Ball, Ken Griffin, Rick McLean, Eric Xiao, "Subsection 55(2) material and Part IV", Submission of the Joint Committee, 13 October 2016 -- summary under Subsection 55(2)
Scenario 2 Opco (which has RDTOH but also GRIP balance) pays deemed dividend to Holdco (subject to s. 55(2)), which pays an eligible and ineligible dividend to X generating a dividend refund – but application of s. 55(2) to Holdco permits substantial capital dividend election. ...
Article Summary
Michael N. Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper -- summary under Corporation
[f.n. 23: … 2006-021645117] Effectively taxpayers have since been faced with a "don’t ask, don’t tell" situation. ...
Article Summary
Michael N. Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper -- summary under Section 96
[f.n. 23: … 2006-021645117] Effectively taxpayers have since been faced with a "don’t ask, don’t tell" situation. ...