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., because CRA applied s. 67 to deny the deductibility to the first CCPC of fees charged to it by the second CCPC – see 2012-0440071E5). ...

CRA confirmed that such employees are not permitted an s. 20(11) or (12) deduction for the foreign taxes paid on such income in excess of a 15% rate because “unlike paragraph 144(8.1)(b) … there is no provision of the Act which deems any portion of the foreign NBIT paid by an EPSP to have been paid by an employee beneficiary for the purposes of subsection 20(11) or 20(12).” ...

Pubco) received the repayment of a loan that it had made to a non-resident affiliated corporation (Forco2, which was not a foreign affiliate of Canco3), and used the repayment proceeds to purchase note receivables from group companies within the Forco2 silo and also to pay a dividend to Canco3 – which then lent some of this money “back” to Forco2 and also repaid loans owing to Canadian affiliates held in a separate silo from the Canco3 or Forco 2 silos. ...

Cash balances which accumulate only to be depleted in accordance with the annual seasonal fluctuations of the business will generally qualify – but a permanent balance in excess of the company's reasonable working capital needs will generally not qualify. ...

In rejecting the employer’s position, the Directorate stated that “subsection 96(1) … ensures that the members of the partnership are taxable on their respective share of the partnership’s income” and that in applying Reg. 106(1), “the amount to be withheld from the [withdrawal] Payment should be equal to the total amount of tax that may reasonably be expected to be payable under the Act by the members of the employer partnership with respect to the Payment.” ...

Summary of Richard Tremblay and Ilana Ludwin, "Indian Supreme Court Diverges from OECD Guidelines, Relies on Questionable Canadian Precedent, in Deciding PE Issue in Formula One," Tax Management International Journal, 2018, p. 125 under Treaties – Income Tax Conventions- Art. 5. ...

Although this sounds ominous, CRA went on to indicate that the taxpayer’s exemption threshold in this situation would be nil “it is necessary for the taxpayer to have acquired a flow-through share (or certain partnership interests …) in order for a taxpayer to have an exemption threshold in respect of a flow-through share class of property to which subsection 40(12) of the Act would apply.” ...

Summary of BSR REIT preliminary prospectus under Offerings – REIT and LP Offerings- Cross-Border REITs. ...

CRA’s reasoning was that the only interest referenced in this definition was interest that was “paid or payable” – so that the contingent interest could be ignored until it became payable by virtue of the occurrence of the price trigger. ...

Summaries of 7 February 2018 External T.I. 2016-0673331E5 under s. 9 – computation of profit. ...