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In the situation described above, will CRA consider that UKco has a permanent establishment in Canada under Article 5 of the Canada – U.K. ... ASIC Miners ASIC miners, on the other hand, are designed and optimised to perform a single task – mine crypto-assets. ... (iii) Part II Section 3A – Surplus Accounts – 4. Upstream Loan Rules (Table) Column 2 of the Table requires reporting entities to identify if a specified debtor (as defined in subsection 90(15)) owes an amount to the foreign affiliate (or a partnership of which the foreign affiliate was a member) at any time during the reporting period. ...

At the 2015 STEP – CRA Roundtable, CRA stated that an individual can only have one estate. ... Anyone wanting to access that Q & A, can go to the CRA website and use the search tool to enter in “graduated rate estate”- and the Q & A will be the first hit for the search. ... Further, the settlor / grantor can exercise his / her power to revoke the trust at any time. ...

D4- Provincial allocation disputes At one time, the CRA employed a formal process — the Tax Re-Allocation Committee (TRAC) — for resolving provincial allocation disputes. ... E3- "Normal open-market" purchase in s. 39(3) 2014-0550401C6 E – 2014 TEI Liaison Meeting, Q. ... E6- S. 115.2(2)(b)(i)(B)- Forco share issuance to affiliated Canco 2014-0550421C5 E – 2014 TEI-CRA Liaison Meeting – Question E6 – Non-Resident Carrying on Business in Canada Where a non-resident engages a Canadian investment manager, the activities of the investment manager may cause the non-resident to be carrying on business in Canada for Canadian tax purposes. ...

.), substantially for the reasons offered in the T.C.C. judgment (" Alco Dispensing ")], M.N.R. v. ... The Petit Robert de la langue française defines the term "actif" [“asset”] as “l’ensemble des biens ou droits constituant le patrimoine “ ["all the property or rights constituting the patrimony"]. ... In a self‑assessing tax system such as that provided for in the Act, taxpayers should have confidence that the Minister is administering and enforcing the same tax laws in the same way for everyone (pp. 33-34 and 68). [26] Practically, this constrains the Minister to assess a taxpayer in accordance with the facts of the matter ⸺ here, the transactions ⸺ and the law (CIBC World Markets Inc. v. ...

The preamble to s. 104(4) states that the deemed disposition dates apply to each property of the trust – that is, the dates are not tied to specific properties. S. 104 might not apply in the circumstance, because s. 108(1) – “trust” – (g) generally provides that the s. 104(4) will not apply to a trust in which all interests have vested indefeasibly. ... The result is the same as it was in the first scenario for the person who is just the shareholder in that s. 15(1.4)(c) won’t apply, for the same reason – the amount of the wages are already included in the shareholder’s income – in this case, the shareholder-employee’s employment income. ...

Process for inital contact – do requests go to taxpayer, representatve, or both? ... Process for initial contact – do requests go to taxpayer, representative, or both? ...

Physical cash-pooling involves actual transfers of cash within accounts in the cash pool; notional cash-pooling does not – there can be positive and negative balances as long as the overall balance is zero or positive. ... Thus, for the purposes of computing the numerator of the fraction – the net income of the foreign affiliate from the FAPI business – it is necessary to first identify the activities that would form part of FAPI business and, when that is reasonably determined, then the gross income under the foreign tax rules from that FAPI business is to be computed, with that amount then being reduced by the total amount of deductions that are allowed under the foreign tax law and claimed by the foreign affiliate in the taxation year that may reasonably be regarded as directly applicable only to the FAPI business; this amount should also be reduced by the prorated amount of deductions (again allowed under the foreign tax law and claimed by the foreign affiliate) that would not reasonably be regarded as applicable to either the FAPI business or any other income-generating activities, such as overhead or head office expenses. ... That fraction is multiplied by the total foreign tax paid by the foreign affiliate to arrive at the amount of foreign tax that may be regarded as applicable to FAPI – that figure is then converted into Canadian dollars pursuant to s. 261. ...

Such assets might be disposed of before the acquistion – or immediately after the acquisition. ... XXVI and Annex A, there were (per Susan) very few cases of ultimate double taxation, the presence of arbitration has speeded (by approximately 1/3) the resolution of Mutual Agreement Procedure cases due to the incentive for the two competent authorities to grapple with the more difficult issues on a more expeditious basis – and (per Susan) the resulting habit of greater efficiency also has speeded the handling of MAP files for third countries. The dialogue in a MAP case will be continued for so long as it can be carried forward (per Patricia) – and even if arbitration has commenced, the two authorities will continue to try to resolve the dispute consensually. ...

However it is not clear that this is still the practice under the new voluntary disclosure program, since disclosure officers say they now just make their relief decisions, the returns submitted with the disclosure are then sent “for processing” – and they don’t know how processing is handled. ... c) Would the registrant’s disclosure application be considered as Category 1 – wash transactions (100% penalty and interest relief) or Category 2-general (100% penalty and 50% interest relief) if returns were not filed for 7 years, but all the uncharged HST involved wash transactions? ... Company A will re-supply points to Company B to be issued by Company B to retail customers upon earning points – or to independent dealers to be issued to retail customers of those dealers. ...

Therefore using Bitcoins to purchase goods or services would be treated as a form of barter transaction ….” ... Under s. 225.2(2), the SLFI is required to determine its net tax under the formula [(A-B) x C x (D/E)]- F + G (SAM Formula). ... S. 228(2.3) provides that “where a person who is a [SLFI] is required to file a final return … (a) the person shall calculate … the net tax … (b) where the net tax of the person… is a positive amount, the person shall remit that amount to the Receiver General on or before the day the final return for the reporting period is required to be filed.” ...