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11 January 2024- 12:28am Joint Committee notes that Pangaea is undercutting the ITA’s policy not to impose Part XIII tax on cross-border payments to arm’s-length debenture holders Email this Content In a 2020 submission, the Joint Committee expressed concerns that a broad reading of Pangaea could result in the imposition of Part XIII tax on commitment fees, and consent fees and restructuring fees, paid to arm's length non-resident lenders/ debt holders – which would run contrary to the policy choice made to reduce the cost of capital to Canadian businesses by eliminating the withholding tax payable to arm's-length lenders. ...

12 January 2024- 2:01am The increase in the AMT exemption will increase the tax-free level of dividends which an individual can receive Email this Content Two benefits of the increase in the AMT exemption from $40,000 to $173,205 going from 2023 to 2024: In 2023, a Canadian individual taxpayer with income of $55,000 that consisted solely of eligible dividends would not be subject to federal tax, but would be subject to AMT on eligible dividends in excess of $55,000 until the regular net federal tax payable exceeded the minimum amount – whereas for 2024 and subsequently, income consisting only of eligible dividends will not generate AMT at any income level. ...

The position in 9640475 – that s. 128.1(4)(b) would apply to tax the individual on the emigration as if the declared and unpaid dividend had been paid- appears to be incorrect. ...

Summaries of 17 November 2023 External T.I. 2023-0965891E5 under s. 115.2(1) – Designated investment services, paras. ...

In other words, “anticipation” of insolvency includes reasonable “avoidance” of insolvency – even where the individuals concerned may have been the authors of their own misfortune. ...

. … Neal Armstrong. Summary of 19 November 2019 Roundtable, 2019-0829611C6 under s. 212(2). ...

CRA has viewed a French société en commandite simple as a partnership, irrespective of whether it has irrevocably elected to be taxed as a corporation in France – and similarly, the recent enactment of reverse hybrid rules in Luxembourg would not be determinative. ...

Nonetheless, a Quebec general or limited partnership has many of the characteristics typically associated with legal personality such as being able or subject to suing or being sued in its own name, and having a separate patrimony – and CRA has “previously stated that the existence of a separate legal personality alone is generally not sufficient to distinguish certain foreign partnerships from Canadian partnerships.” ...

CRA indicated that such a request could be granted since it would have no impact on the tax payable for the particular year, but “emphasize[d] … that there is nothing in the Act that compels the Minister to automatically accept such requests.” ...

19 June 2024- 11:18pm CRA indicates that the TCC has confirmed its view that an amount paid by a trust to a beneficiary is not deductible under s. 104(6) if it was not payable under the trust deed Email this Content CRA referred to an unreported 2023 Tax Court decision (which has not been appealed) regarding a family trust that realized a capital gain, paid $100,000 to each of two minor beneficiaries in the same taxation year, and claimed the deduction therefor pursuant to s. 104(6)(b) – notwithstanding that the trust deed prohibited any distributions to designated persons in respect of the father. ...