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News of Note post
28 July 2021- 10:29pm Ménard – Court of Quebec applies the kiddie tax to a trust’s distribution of a capital gain, realized on a crystallization transaction, to a minor beneficiary Email this Content In 2012, a discretionary family trust engaged in a capital gains crystallization transaction in which it disposed of shares, having a modest ACB, of a small business corporation wholly-owned by the trust in consideration for shares of a new class of the same corporation, and then allocated and distributed the capital gain to its beneficiaries, one of whom was a minor. ... The statutory language relevantly required that an “amount can reasonably be considered to be attributable to a taxable capital gain … of a trust from a disposition of shares … that are transferred, either directly or indirectly … to a person with whom the specified individual does not deal at arm's length….” Taxpayer’s counsel argued that this language required that there be two distinct transactions – first, a disposition, and second, a transfer – whereas here the disposition and the transfer instead were one and the same transaction. ...
News of Note post
11 December 2018- 11:46pm Adecco – English Court of Appeal finds that a placement service providing non-employee temps to clients was not paying the temps’ compensation on the clients’ behalf Email this Content An employment bureau (Adecco) introduced temporary staff ("temps"), who were not Adecco employees, to clients looking for a temporary worker to undertake an assignment, and if the temps accepted an assignment, Adecco paid them for the work they did for the clients – and collected those amounts plus a mark-up from the clients. ... Summary of Adecco UK Ltd & Ors v Revenue & Customs [2018] EWCA Civ 1794 under s. 123(1) – consideration. ...
Current CRA website
Self-employment income Lines 13499 to 14299 – Gross income and Lines 13500 to 14300 – Net income
Self-employment income Lines 13499 to 14299 – Gross income and Lines 13500 to 14300 – Net income Note: Lines 13499 to 14299 were lines 162 to 170 and lines 13500 to 14300 were lines 135 to 143 before tax year 2019. ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – Chapter 4: Page 4 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 4: Page 4 of the T2 return On this page... Small business deduction Avoidance of the business limit and taxable capital limit Preventing multiplication of the small business deduction Line 400 – Income from active business carried on in Canada Active business income Specified investment business Personal services business Specified shareholder How to calculate income from an active business carried on in Canada Specified partnership income Line 405 – Taxable income for the SBD Line 410- Business limit Line 425 – Reduced business limit Assignment of the business limit under subsection 125(3.2) Line 430 – Small business deduction Small business deduction Corporations that were Canadian-controlled private corporations (CCPCs) throughout the tax year may be able to claim the small business deduction (SBD). ... To calculate the total taxable capital employed in Canada, use whichever one of the following schedules that applies: Schedule 33, Taxable Capital Employed in Canada – Large Corporations; Schedule 34, Taxable Capital Employed in Canada – Financial Institutions; or Schedule 35, Taxable Capital Employed in Canada – Large Insurance Corporations. ...
Current CRA website
T2 Corporation – Income Tax Guide – Chapter 4: Page 4 of the T2 return
T2 Corporation – Income Tax Guide – Chapter 4: Page 4 of the T2 return On this page... Small business deduction Avoidance of the business limit and taxable capital limit Preventing multiplication of the small business deduction Line 400 – Income from active business carried on in Canada Active business income Specified investment business Personal services business Specified shareholder How to calculate income from an active business carried on in Canada Specified partnership income Line 405 – Taxable income for the SBD Line 410- Business limit Line 425 – Reduced business limit Assignment of the business limit under subsection 125(3.2) Line 430 – Small business deduction Small business deduction Corporations that were Canadian-controlled private corporations (CCPCs) throughout the tax year may be able to claim the small business deduction (SBD). ... To calculate the total taxable capital employed in Canada, use whichever one of the following schedules that applies: Schedule 33, Taxable Capital Employed in Canada – Large Corporations; Schedule 34, Taxable Capital Employed in Canada – Financial Institutions; or Schedule 35, Taxable Capital Employed in Canada – Large Insurance Corporations. ...
1 January 2014- 10:36pm McKesson – Tax Court of Canada reduces a cross-border receivables financing rate from 27% to 12.5% p.a. ... However, he was inclined to think that it was inappropriate to (and he did not) impute changes to the fundamental terms of the deal – for example, by inquiring what the terms would have been if the receivables had been sold on a recourse rather than a non-recourse basis. ... The Queen, 2013 TCC 404 under s. 247(2), s. 247(4), Treaties – Art. 9, General Concepts – Intention and General Concepts – Evidence. ...
Article Summary
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114 -- summary under Paragraph (c)
Tina Korovilas, Drew Morier, "Non-Corporate Vehicles in the Foreign Affiliate Context", 2018 Conference Report (Canadian Tax Foundation), 20:1 – 114-- summary under Paragraph (c) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(1)- Excluded Property- Paragraph (c) Initial concern re s. 95(1) – EP – para. (c) that property of the partnership could not qualify (pp. 20:56-59) When the EP definition was first proposed in 1982, the draft provision raised concerns that property of the partnership could not qualify as property of the FA. … The tax community expressed a concern that where an FA has an interest in a partnership that carries on an active business, the partnership interest of the FA could qualify as EP, but partnership property used for the purpose of gaining or producing income from an active business could not so qualify … [so] that where a partnership of which a foreign affiliate is a member disposes of capital property used principally for the purpose of gaining or producing income from an active business, the property does not qualify as excluded property …. … Although the current definition continues to refer to property “of the” FA, it has been accepted that the partnership postamble resolves the concern that arises where partnership property has been disposed of. ...
News of Note post
13 November 2018- 12:31am Iberville Developments – Quebec Court of Appeal finds that it is abusive to use rollover provisions to avoid rather than defer tax Email this Content Three affiliated Quebec corporations avoided (or so they thought) most of the Quebec tax on the sale of Quebec real estate at a gain of around $800M (including some recapture) by using a “Quebec year-end shuffle.” ... Agence du Revenu du Québec, Quebec Court of Appeal No. 500-09-026184-168 (November 12, 2018) under s. 245(4), s. 9 – capital gain v. profit – real estate and s. 18(1)(b) – capital expenditure v. expense – improvements v. running expenses. ...
Article Summary
Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper -- summary under Paragraph 80(2)(k)
Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper-- summary under Paragraph 80(2)(k) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(2)- Paragraph 80(2)(k) Facts of conversion of DIP financing and USD bonds to equity (pp. 7-8) Canco has US$1 billion of bonds (the " Bonds ") payable to unrelated parties (the " Bondholders ")… [who] do not constitute a "group of persons"…. ... An unrelated Canadian corporation (" Buyer ") proposes to provide US$200 million of debtor-in-possession (" DIP ") financing. … Buyer anticipates that after Canco emerges from CCAA, Buyer will own approximately 67% of the shares of Canco (with a fair market value of US$200 million) as a result of Buyer receiving shares of Canco in complete settlement of the DIP financing, and the Bondholders will receive shares of Canco representing 33% of the issued and outstanding Canco shares (with a fair market value of US$100 million) in complete settlement of the Bonds. ... Making an election for subsection 256(9) not to apply in this "same day" situation would reverse the sequence of events so that the Bond settlement occurs before the DIP financing (and resulting LRE). … Comparison of two sequences (pp. 10-11) The CAD$270 million difference is attributable to different foreign currency capital loss amounts – a CAD$300 million foreign currency capital loss under the DIP financing settlement – bond settlement sequencing, versus a CAD$30 million foreign currency capital loss under the Bond settlement – DIP financing settlement sequencing. ...
Technical Interpretation - Internal summary
15 January 2007 Internal T.I. 2006-0216801I7 - Redemption of US $ Denominated Shares -- summary under Subsection 39(2)
15 January 2007 Internal T.I. 2006-0216801I7- Redemption of US $ Denominated Shares-- summary under Subsection 39(2) Summary Under Tax Topics- Income Tax Act- Section 39- Subsection 39(2) s. 39(2) application on USD pref redemption, cf. if USD common shares The redemption of U.S. ... However, the Directorate noted its previous comments that MacMillan Bloedel “ deals with the redemption of redeemable and retractable preferred shares, which may be viewed as similar to the repayment of a debt obligation” and it is “not prepared to extend the reasoning to a redemption of shares in general.” ...