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" under “Scenario 2” under s. 120.4(1) – related business. ...

" under “Reasonable return” under s. 120.4(1) – “reasonable return”. ...

Summaries of GST/HST Memorandum 20-3 “Universities” December 2019 under ETA s. 123(1) – university, Sched. ...

He could instead transfer ½ of his Opco shares on a rollover basis to newly-formed Holdco, with Holdco then realizing a $500,000 capital gain on those shares on an internal transfer, so that Holdco is subject to $127,000 of corporate tax, has a $250,000 addition to its CDA and generates $77,000 of non-eligible RDTOH. ...

Multi-Family (No. 1) Value-Add Fund Circular under Other – Asset Purchases. ...

22 January 2020- 11:44pm CRA indicates that a grandfathered LLLP cannot treat itself prospectively as a corporation without losing grandfathering Email this Content 2017-0691131C6 stated that one of the conditions for allowing Delaware or Florida LLLPs formed before April 26, 2017 to file as a partnership was that “no member of the entity and/or the entity itself takes inconsistent positions from one taxation year to another … between partnership and corporate treatment.” ...

After noting that “where a loss from a subsequent taxation year is carried back to a particular taxation year, the revised income taxes payable and any resulting refund are computed using the exchange rates applicable to that particular year, regardless of the exchange rate in the subsequent year,” CRA indicated that this situation was essentially dealt with in Folio S5-F2-C1, which addresses the reverse situation of FX gains in Canadian dollars on foreign tax refunds or payments – so that, here, the FX gain was a capital gain to be computed based on the FX rate change between that appliable to the previous year and that at the time of receipt. ...

Summary of Michael Kandev and John Lennard, "The OECD Multilateral Instrument: A Canadian Perspective on the Principal Purpose Test", Bulletin for International Taxation, January 2020, p. 54 under Treaties- MLI – Art. 7(1). ...

The report found that it was abusive and improper for the ARQ to reassess without an adequate evidentiary foundation capable of surviving judicial scrutiny – and that, in such instances, the reassessment should be dropped. ...

Summary of May 2019 CPA Alberta CRA Roundtable, GST Session – Q.3 under ETA s. 211(5)(c). ...