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Summary of 19 January 2017 Ruling 172004 under ETA s. 123(1) – supply. ...

CRA did not mention s. 52(2), which provides that property paid as a dividend in kind is deemed to have been disposed of and acquired at its FMV – perhaps because it thought it was obvious that s. 52(2) was trumped by s. 148(7). ...

Summary of 2016 Ruling 2015-0612931R3 under s. 248(1) – disposition. ...

On the other hand, if there instead is no indirect debt and the $30 direct debt to Canco is funded entirely or at least as to $20 out of surplus funds derived from the intermediary's operations, the shareholder of the intermediary effectively will be considered under the formula to have funded the entire amount of the $30 direct loan even though its share capital account was only $10 – so that Canco will be deemed under the formula to have paid all the interest under the direct loan to that shareholder. ...

In any event, errors by large corporations typically are attributable to the number and complexity of the tax-reporting issues faced by them, so that their exclusion would violate fundamental principles of fairness – as does the blanket denial of relief to taxpayers respecting transfer pricing errors. ...

First, CRA essentially was reading the requirement in s. 231.1(1)(d)- that personnel at the audited premises “answer all proper questions relating to the administration…of this Act” – out of context. ...

. … Furthermore, if an auditor is assessing net tax for the claim period in question, an allowable unclaimed rebate amount for that period must be applied against the assessment of net tax. ...

If TP was unrelated to BP (meaning, broadly, that it had a minority interest), TP would be able under s. 80(9) to apply its deemed forgiven amount first against the ACB of its BP partnership interest that was disposed of on the winding-up and which was increased by the amount of the s. 80(13) income allocated to it – so that there would be a reduced, or no, amount of remaining s. 80(13) debt forgiveness income to be allocated by TP to its partners. ...

Summary of 28 April 2017 Interpretation 154249 under ETA s. 123(1) – recipient. ...

(Butterfly rulings typically have prorated UCC based on relative FMV – see e.g., 2014-0530961R3 and 2013-0498651R3). ...