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Reasons: Interpretation of the Act and previous positions. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 10. ...

The supporting documents requested by the CRA are proof of payment of that confirmed final tax liability. 2023 STEP CRA Roundtable – June 20, 2023 QUESTION 18. ...

The same document confirms the CRA’s view that “similar” is to be interpreted narrowly, stating, “ In our view, the word “similar” in the context of subsection 111(5) of the Act has a narrower meaning than “having characteristics in common” and should be interpreted as “of the same general nature or character”. ... Canadian Western Natural Gas, Light, Heat & Power Co. ((1922) 69 DLR 401 (Alta SC (AD)). ... George Thompson & Company, Limited (1927), 13 TC 83 (Eng. KB) (“Scales”) sets out the test for the determination of whether certain operations are a separate business. ...

When describing how the purpose is to be established, paragraphs 178 and 179 of the Commentary indicate that the PPT is an objective-subjective standard considering all the relevant facts and circumstances to determine if obtaining a treaty benefit was one of the principal purposes of the arrangement or transaction: “178. […] What are the purposes of an arrangement or transaction is a question of fact which can only be answered by considering all circumstances surrounding the arrangement or event on a case-by-case basis. It is not necessary to find conclusive proof of the intent of a person concerned with an arrangement or transaction, but it must be reasonable to conclude, after an objective analysis of the relevant facts and circumstances, that one of the principal purposes of the arrangement or transaction was to obtain the benefits of the tax convention. […]” 179. ...

Position: See response. 2011 TEI-CRA Liaison Meeting December 6, 2011 Question 10- Transfer Pricing (1) Michael Danilack, Deputy Commissioner (International), Large Business & International, of the Internal Revenue Service made remarks during TEI's 61st Midyear Conference in Washington, D.C. ...

Yves Moreno / François Mathieu 2015-057382 ...

To quote from CRA Views # 2009-0347291C6 (which provides both the English and French versions of question #3 from the Foundation's Roundtable), "whether a corporation has conferred a benefit on a shareholder for subsection 15(1) ITA purposes is generally one of fact. ...

Poulin wanted to leave Amiante, selling his interest in it at the best price and under the most optimal possible conditions — one of which was to benefit from his capital gains deduction. ...

Nous informerons les sociétés de l'impact des IFRS sur le calcul du revenu imposable dans une prochaine parution d'un bulletin de nouvelles techniques et / ou sur notre site internet, dès que notre étude sera complétée. ...

Sherry Thomson International & Trusts Division Income Tax Rulings Directorate ENDNOTES 1 'The OECD Commentary states that in "abusive situations" the formal legal employment relationship should be ignored and an analysis of the functions performed should be undertaken in order to determine who the true employer is. ...